Incorporating Third-Party Cybersecurity Risk into Internal Audit Planning and Execution

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Incorporating Third-Party Cybersecurity Risk into Internal Audit Planning and Execution

Internal Audit, Governance and Data Protection

Published on: Feb 16, 2025

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Third-party vendors often represent significant cybersecurity vulnerabilities. Internal auditors must evaluate how organizations manage supplier risk, ensuring that outsourced services and business partners do not compromise data security or compliance obligations.

Organizations increasingly rely on third-party vendors for cloud hosting, payroll, customer support, and software development. While outsourcing can reduce costs and improve efficiency, it also creates cybersecurity risks that are frequently overlooked. Internal auditors play a critical role in evaluating how well management oversees third-party relationships.

The first step is to assess whether the organization maintains an inventory of all third-party providers. Without visibility into who vendors are and what data they access, risks cannot be effectively managed. Auditors should review contracts, service level agreements (SLAs), and vendor access logs to confirm accuracy and completeness.

Vendor due diligence is another critical area. Before onboarding, organizations should assess vendor cybersecurity posture through questionnaires, security certifications (e.g., SOC 2, ISO 27001), and penetration testing results. Auditors should evaluate whether these assessments are being conducted and whether high-risk vendors undergo enhanced scrutiny.

Ongoing monitoring is equally important. Cybersecurity risks do not end once a vendor is onboarded. Internal audit should verify that vendors are subject to periodic reviews, including compliance checks and security audits. If vendors have direct access to internal systems, auditors should ensure monitoring mechanisms are in place to detect suspicious activity.

Incident response planning must also consider third parties. Auditors should determine whether contracts specify vendor responsibilities during a cyber incident and whether communication protocols are clearly defined. Inadequate response coordination can worsen the impact of an attack.

Additionally, auditors should consider regulatory implications. Data privacy laws such as GDPR and CCPA require organizations to ensure that third parties protect personal data. Failure to enforce vendor compliance can result in significant penalties and reputational damage.

Ultimately, internal auditors must highlight to management and the board that third-party risk is not just an IT concern but a business risk. Audit reports should quantify the potential impact of vendor-related breaches and recommend improvements to risk assessment, contract management, and oversight processes.

By incorporating third-party cybersecurity risk into audit plans, internal auditors strengthen organizational defenses against one of today’s most overlooked but significant threats.