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Vendor Management Policy

This page describes Data Migrators’ policy and procedures around risk management.

Overview

See Purpose.

Purpose

The purpose of the Data Migrators Vendor Management Policy is to describe the actions and behaviors required to ensure that due care is taken to avoid inappropriate risks to Data Migrators, its business partners, and its stakeholders from any of its vendors.

Audience

The Data Migrators Vendor Management Policy applies to any individuals that interacts with, establishes relati0onships with or manages any Data Migrators vendors.

Policy

Assessments

  • Vendors granted access to Data Migrators Information Resources must sign the Data Migrators Vendor Non-Disclosure Agreement/Business Associate Agreement.
  • Vendors must be evaluated prior to the start of any service and thereafter on an annual basis.
  • High risk findings must be followed up to verify remediation.
  • A vendor risk assessment must be performed on vendors with physical or logical access to confidential information or that are considered critical vendors.
  • Risk assessments must be performed on all requested cloud providers before approval.
  • Vendors with PCI DSS compliance requirements must have their status reviewed on an annual basis.

Management

  • Vendor agreements and contracts must specify:
    • The Data Migrators information the vendor should have access to,
    • How Data Migrators information is to be protected by the vendor,
    • How Data Migrators information is to be transferred between Data Migrators and the vendor,
    • Acceptable methods for the return, destruction or disposal of Data Migrators information in the vendor’s possession at the end of the contract,
    • Minimum information security requirements,
    • Incident response requirements,
    • Right for Data Migrators to audit vendor.
  • If a vendor subcontracts part of the information and communication technology service provided to Data Migrators, the vendor is required to ensure appropriate information security practices throughout the supply chain and to notify Data Migrators.
  • The vendor must only use Data Migrators Information Resources for the purpose of the business agreement.
  • Work outside of defined parameters in the contract must be approved in writing by the appropriate Data Migrators point of contact.
  • Vendor performance must be reviewed annually to measure compliance to implemented contracts or SLAs. In the event of non-compliance with contracts or SLAs regular meetings will be conducted until performance requirements are met.
  • Vendor’s major IT work activities must be entered into or captured in a log and available to Data Migrators IT management upon request. Logs must include, but are not limited to, events such as personnel changes, password changes, project milestones, deliverables, and arrival and departure times.
  • Any other Data Migrators information acquired by the vendor in the course of the contract cannot be used for the vendor’s own purposes or divulged to others.
  • Vendor personnel must report all security incidents directly to the appropriate Data Migrators IT personnel within the timeframe defined in the contract.
  • Data Migrators will provide a technical point of contact for the vendor. The point of contact will work with the vendor to make certain the vendor is in compliance with these policies.
  • New vendors must provide Data Migrators a list of key personnel working on the contract.
  • Vendors with logical access to information resources must provide non-repudiation authentication mechanisms.
  • Vendors must provide Data Migrators with notification of key staff changes within 24 hours of change.
  • Upon departure of a vendor employee from the contract for any reason, the vendor will ensure that all sensitive information is collected and returned to Data Migrators or destroyed within 24 hours.
  • Upon termination of contract, vendors must be reminded of confidentiality and non-disclosure requirements.
  • Upon termination of contract or at the request of Data Migrators, the vendor must surrender all Data Migrators badges, access cards, equipment and supplies immediately. Equipment and/or supplies to be retained by the vendor must be documented by authorized Data Migrators IT management.

Non-compliance

Personnel found to have violated this policy may be subject to disciplinary action, up to and including termination of employment, and related civil or criminal penalties.

Any vendor, consultant, or contractor found to have violated this policy may be subject to sanctions up to and including removal of access rights, termination of contract(s), and related civil or criminal penalties.

Definitions and Terms

None.