Vendor Risk Management Policy (SEC-POL-005)

1. Objective

This policy establishes comprehensive requirements for assessing, managing, and monitoring security risks associated with third-party vendors and service providers who support [Company Name]’s video streaming platform operations. The policy ensures that all vendors maintain appropriate security standards and comply with regulatory requirements while supporting business operations and protecting user data across all vendor relationships.

2. Scope

This policy applies comprehensively to all third-party vendors, service providers, contractors, and business partners who have access to Company systems, data, or infrastructure across all operational environments. The scope encompasses vendors who provide services critical to video streaming platform operations, including content moderation services, content delivery network (CDN) providers, payment processors, cloud service providers, and technology vendors across all geographic regions.

3. Policy

3.1 Vendor Risk Assessment

  • All vendors must undergo comprehensive security risk assessment before contract execution and periodically thereafter.
  • Initial security assessment must be completed before contract signing for all vendor relationships.
  • Annual reassessments must be conducted for critical vendors to ensure continued compliance.
  • Event-triggered assessments must be performed when significant changes occur in vendor operations or security posture.
  • Risk-based assessment frequency must be determined based on vendor criticality and data access levels.

3.2 Vendor Classification

Vendors shall be classified based on their risk level and criticality to platform operations:

Critical Vendors:

  • Content delivery network (CDN) providers
  • Cloud infrastructure providers
  • Content moderation services
  • Payment processing providers
  • Primary data center operators

High-Risk Vendors:

  • Analytics and user behavior tracking services
  • Customer support platform providers
  • Marketing and advertising technology vendors
  • Security tool providers
  • Backup and disaster recovery services

Standard Vendors:

  • Office productivity software providers
  • HR and recruitment platform providers
  • General business services
  • Non-critical software tools

3.3 Security Requirements by Vendor Type

Content Moderation Services:

  • SOC 2 Type II certification required
  • Content reviewer background checks and training
  • Secure content review environments with monitoring
  • Content data encryption and secure disposal
  • Compliance with platform content policies

CDN Providers:

  • Global security operations centers (SOCs)
  • DDoS mitigation capabilities
  • Geographic content blocking capabilities
  • Real-time threat intelligence integration
  • Secure content caching and delivery protocols

Payment Processors:

  • PCI DSS Level 1 certification required
  • Strong customer authentication (SCA) compliance
  • Fraud detection and prevention capabilities
  • Secure tokenization of payment data
  • Regular penetration testing and vulnerability assessments

3.4 Contract Security Requirements

All vendor contracts must include:

  • Security and privacy requirements specific to the vendor’s role
  • Data protection clauses compliant with GDPR, CCPA, and other applicable laws
  • Incident notification requirements (within 24 hours)
  • Right to audit security controls and practices
  • Termination clauses for security violations
  • Data return and destruction requirements upon contract termination

3.5 Ongoing Vendor Management

Continuous vendor oversight includes:

  • Regular review of security certifications and attestations
  • Monitoring of vendor security incidents and breaches
  • Performance monitoring against security SLAs
  • Regular communication regarding security updates and changes
  • Vendor security training and awareness programs

3.6 Vendor Access Management

Vendor access to Company systems and data must be:

  • Limited to minimum necessary for service delivery
  • Monitored and logged for all access activities
  • Protected by multi-factor authentication
  • Subject to regular access reviews and recertification
  • Terminated immediately upon contract completion

3.7 Fourth-Party Risk Management

Vendors must disclose and manage risks from their subcontractors:

  • Documentation of all critical subcontractors
  • Security assessments of fourth parties handling Company data
  • Contractual flow-down of security requirements
  • Notification of subcontractor changes that may impact security

4. Standards Compliance

Policy Section Standard/Framework Control Reference
3.1, 3.2 ISO/IEC 27001:2022 A.15.1.1
3.1, 3.2 PCI DSS v4.0 Req. 12.8.1
3.3 SOC 2 Type II CC9.2
3.3 PCI DSS v4.0 Req. 12.8.2
3.4 GDPR Art. 28
3.4 CCPA § 1798.140(w)
3.4 PCI DSS v4.0 Req. 12.8.3
3.5 ISO/IEC 27001:2022 A.15.2.1
3.5 PCI DSS v4.0 Req. 12.8.4
3.6 NIST Cybersecurity Framework PR.AC-4
3.6 PCI DSS v4.0 Req. 8.1, 8.2

5. Definitions

Vendor: Any external organization that provides goods or services to [Company Name] under a contractual agreement.

Critical Vendor: A vendor whose service disruption could significantly impact platform operations, user safety, or regulatory compliance.

Fourth Party: A vendor’s subcontractor or service provider that may have access to Company data or systems.

Content Delivery Network (CDN): A distributed network of servers that deliver video content to users based on their geographic location.

Data Processing Agreement (DPA): A contract that defines how personal data is processed by vendors on behalf of [Company Name].

Security Level Agreement (SLA): Contractual commitments regarding security performance, availability, and incident response metrics.

6. Responsibilities

Role Responsibility
Procurement Team Ensure vendor contracts include required security terms and obtain security assessments before contract execution.
Vendor Management Office Coordinate vendor risk assessments, maintain vendor registries, and monitor ongoing vendor performance.
[Security Department/Team Name] Conduct vendor security assessments, review security certifications, and investigate vendor-related security incidents.
[Legal Department/Team Name] Review and approve vendor contract security terms, ensure regulatory compliance, and manage data protection agreements.
Business Owners Define vendor requirements, participate in risk assessments, and monitor vendor service delivery performance.
[Privacy Department/Team Name] Ensure vendor data processing complies with privacy requirements and support data subject rights fulfillment.

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