3rd Party Integration & Vendor Management Policy

Document Version & Control

  • Version: 1.0
  • Last Review Date: 6 Jan 2025
  • Next Review Date: [12 months from the last review or upon significant changes]
  • Approver: CTO, DPO

Purpose & Scope
This policy establishes the framework for evaluating, onboarding, monitoring, and offboarding third-party vendors, service providers, and technology partners (collectively, “vendors”), as well as integrating external APIs, data feeds, or services into our SaaS platform. It ensures that all third-party relationships and integrations adhere to security, compliance, performance, and contractual requirements, while minimizing business and data protection risks.

The scope includes:

  • Vendors providing software, infrastructure, security tools, or professional services.
  • Third-party APIs and data sources integrated with our production environment.
  • Consultants, contractors, or managed service providers with access to client or applicant data.
  • Any external entity that can impact the security, availability, or compliance posture of our SaaS offerings.

Compliance & References

  • Standards & Frameworks: ISO 27001: A.15 (Supplier Relationships), SOC 2 (Security, Availability), NIST SP 800-171 (Protecting Controlled Unclassified Information in Nonfederal Systems)
  • Regulations: PDPA (Singapore), GDPR (if applicable), and any region-specific data protection or industry regulations
  • Related Internal Policies:
    • Information Security Policy
    • Data Management & Database Policies
    • Encryption & Key Management Policy
    • Authentication & Access Control Policy
    • Incident Response & Breach Notification Policy
    • Logging, Monitoring & Audit Policies
    • Change Management & Release Management Policies

Roles & Responsibilities

  • CTO: Approves strategic vendor partnerships and ensures that technical integrations align with enterprise architecture.
  • DPO: Evaluates vendor security posture, ensures compliance with security standards, and signs off on vendor risk assessments.
  • Procurement / Legal & Compliance Officer: Reviews vendor contracts, service agreements, and compliance clauses; ensures data protection and regulatory adherence are addressed in contracts.
  • DevOps & Engineering Teams: Implement and maintain integrations, monitor vendor performance, and ensure adherence to technical requirements.
  • Security & Compliance Team: Conducts vendor security assessments, periodic audits, and monitors ongoing compliance with security and data protection standards.
  • Internal Audit (If Applicable): Periodically reviews adherence to this policy, vendor risk management procedures, and documentation.

Vendor Selection & Onboarding

  1. Vendor Evaluation Criteria:
    • Assess vendors based on security certifications (e.g., ISO 27001, SOC 2), privacy practices, financial stability, technical capabilities, and track record.
    • Review their data handling procedures, breach notification commitments, and compliance with applicable regulations (e.g., PDPA, GDPR).
  2. Risk Assessment & Due Diligence:
    • Perform a vendor risk assessment before onboarding any critical or high-risk vendor.
    • Evaluate the vendor’s security posture, including encryption practices, access control measures, incident response capabilities, and previous breach history.
  3. Contractual Agreements & SLAs:
    • Ensure contracts and service-level agreements (SLAs) include confidentiality, data protection, encryption, and availability commitments.
    • Include clear termination, renewal, and audit clauses.
    • Document roles, responsibilities, and escalation paths for incident handling.
  4. Access Control & Integration Setup:
    • Grant vendor accounts or integration keys based on least privilege, following the Authentication & Access Control Policy.
    • Enforce MFA and secure API tokens or keys.
    • Document integration points, data flows, and dependencies in a centralized repository.

Vendor & Integration Management

  1. Ongoing Monitoring & Performance Reviews:
    • Monitor vendor performance against agreed SLAs, availability targets, response times, and security metrics.
    • Use logging and monitoring tools to detect anomalies or performance degradation related to vendor services or integrations.
  2. Change Management for Integrations:
    • Treat updates to vendor-provided software or changes to third-party integrations as per the Change Management & Release Management Policies.
    • Test new versions, patches, and upgrades in a staging environment before production deployment.
  3. Data Protection & Privacy:
    • Ensure vendors accessing or processing sensitive client/applicant data adhere to our Data Management & Database Policies and Encryption & Key Management Policy.
    • Validate that vendors comply with applicable data residency and privacy regulations, and that data transfers are secured (e.g., TLS).
  4. Incident Response Coordination:
    • Establish clear communication channels and escalation procedures if an incident involves a vendor’s service or integration.
    • Follow the Incident Response & Breach Notification Policy to coordinate investigations, containment, and breach notifications, ensuring the vendor cooperates and provides timely information.

Periodic Assessments & Audits

  1. Annual Vendor Review:
    • Conduct periodic (e.g., annual) reviews of critical vendors to reassess risk, compliance posture, SLA adherence, and overall business alignment.
    • Update risk assessments and vendor profiles as new information emerges.
  2. Security & Compliance Audits:
    • Request or review vendor security audit reports (e.g., SOC 2 Type II, ISO 27001 certificates) annually or upon renewal.
    • Perform internal audits of vendor management processes to ensure compliance with this policy and regulatory requirements.
  3. Continuous Improvement:
    • Incorporate lessons learned from incidents, audits, or vendor performance issues into vendor selection criteria, contractual terms, or security requirements.
    • Update policies and procedures as industry best practices and regulatory standards evolve.

Vendor Offboarding & Contract Termination

  1. Contract Review & Termination Process:
    • Initiate contract termination procedures as per the agreement terms.
    • Provide written notice and ensure data return or secure data destruction is documented.
  2. Access Revocation & Data Sanitization:
    • Revoke vendor access credentials, API keys, and integration points immediately upon contract termination or offboarding.
    • Ensure that all vendor-stored data is returned or securely destroyed, per Data Management & Database Policies and Data Destruction Policy.
  3. Post-Offboarding Review:
    • Evaluate the offboarding process and confirm that no residual access or dependencies remain.
    • Update documentation, risk assessments, and vendor lists accordingly.

Compliance & Exceptions

  • Regulatory Compliance:
    Comply with PDPA, GDPR (if applicable), and other relevant regulations. Ensure vendor contracts align with data protection requirements.

  • Exceptions:
    Any exceptions to this policy must be documented and approved through a formal risk acceptance process overseen by the DPO and CTO.

Training & Awareness

  • Staff Training:
    Provide training to procurement, legal, security, and technical teams on vendor risk management processes, contract requirements, and secure integration practices.

Policy Review & Maintenance

  • Review Cycle:
    Review this policy at least annually or after significant regulatory, business, or technological changes.
    Update policies and related procedures to address evolving vendor landscapes, emerging threats, and new compliance requirements.

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