Due Diligence and Ongoing Monitoring

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Due Diligence Owner

  • 1.  Due Diligence Owner

    Posted 11-05-2019 04:27 PM
    ​Curious about people's experiences here. I manage a decentralized VM program in which my business owners are responsible for completing due diligence on their vendors. Vendor Management reviews and rates their work, but I wonder if I'd be better served by having VM do the due diligence work ourselves. I have low confidence in the quality of my business owners' work and it's perpetually late. I understand this, because conducting DD is not a core strength for any of them and they have other things to do. We've only recently expanded our VM function to the point where we would even have the resources to do this work for our business owners.

    Has anyone worked in both types of systems? If so, what worked better? Were there any cons to having the VM function manage DD?


  • 2.  RE: Due Diligence Owner

    Posted 11-05-2019 04:35 PM
    ​We have found if we require it to be done and done well, we, vendor management, has to control it.  We keep the business users informed and involved but we facilitate the process and all of the due diligence gathering.


  • 3.  RE: Due Diligence Owner

    Posted 11-05-2019 04:52 PM
    We have a centralized VM Program, with a Vendor Program Manager responsible for the policies, processes, monitoring, and metrics.  Individual vendor managers are the relationship managers for their own vendors that follow the centralized process, due diligence, contracts, etc.


  • 4.  RE: Due Diligence Owner

    Posted 11-05-2019 04:55 PM
    Thanks, Michele. That's the system we also have in place today. Do you have confidence in the work your business owners perform? And are they (relatively) on time?​


  • 5.  RE: Due Diligence Owner

    Posted 11-05-2019 04:58 PM
    No I do not have confidence that they are really understanding the relationship conversation, what to review in the information they are collecting.  But that is the risk that has been accepted.  The areas of where big risk such as security, our ISO reviews the SOCS, financial, our CFO reviews financials, and contracts are reviewed by attorney.  The key concerns I have are with the new data privacy laws coming thru and will the vendor managers know the right questions to ask there, and ensure the protections are put in every relationship, contract.  Education will be key here, but a program needs to be put into place first.


  • 6.  RE: Due Diligence Owner

    This message was posted by a user wishing to remain anonymous
    Posted 11-06-2019 10:40 AM
    This message was posted by a user wishing to remain anonymous

    We still have it fragmented, but for our group (which has many of the critical vendors), the onboarding due diligence is done by me, along with Infosec Manager.  We do this to keep some oversight and separation of duties. The annual due diligence is done by me, but I have some periodic that I require the relationship manager to do.


  • 7.  RE: Due Diligence Owner

    Posted 11-05-2019 04:53 PM
    Thank you, Tracy. I'm starting to come to the same conclusion. ​


  • 8.  RE: Due Diligence Owner

    Posted 11-05-2019 04:36 PM
    This is interesting, our auditor has informed me that we should be having our business owners review the SOC reports. She thinks they are the best ones to know the systems, and typically I might agree, except I have 40 years banking experience and have worked on every software the bank has so not sure I agree.   When the business owners review do they fill out a checklist, send you a report or what do you get back from them?​


  • 9.  RE: Due Diligence Owner

    Posted 11-05-2019 04:51 PM
    We have a SOC review checklist template that they use to confirm they've reviewed it. But I agree - I have more confidence in my ability to review a SOC report than I have in my business owners.​


  • 10.  RE: Due Diligence Owner

    Posted 11-07-2019 08:29 AM

    Hello,

     

    Would you be willing to share the SOC review checklist you mentioned in a previous Third Party post?  Our ISO reviews the reports, but audit has recommended we involve business units at some level with a checklist. I took a year and couldn't sell it to the ISO, until he realized some applications are maintained by a business unit, on third party hosted servers, and can be accessed from outside our network.

     

    Thanks,

     

    Josh Courson | Financial Analyst

    Finance Department – Business Performance Unit



  • 11.  RE: Due Diligence Owner

    Posted 11-05-2019 05:14 PM
    Over the past year we have revamped our vendor due diligence process and held firm wide trainings to get all stakeholders up to date on our process. We have Vendor Relationship Managers (VRMs) who are responsible for the vendor relationship. Our Risk & Controls team takes the lead in coordinating the actual due diligence being performed. We handle the due diligence calendar for each vendor and submit the questionnaires to each vendor. The VRMs are responsible for reviewing their specific vendor's profile annually and making Risk and Controls aware of any changes to the relationship so we are aware of what type of questionnaire to send vendors. Also, if we do not hear back from vendors or, have follow up questions on information provided by the vendor, the VRM will help to coordinate requests, follow ups, and any necessary meetings/calls. When a vendor responds to our questionnaire the Risk and Controls team reviews the questionnaire for completeness and then submits oversight tasks to the responsible subject matter experts (BCP, Information Security, Operational including SOC Reports, and Data Privacy) to complete their review of the questionnaire responses and any provided reports/policies/procedure documents. Once each SME completes their review the Risk and Controls team performs an inherent and residual risk assessment on the vendor that is reviewed and accepted by the VRM.


  • 12.  RE: Due Diligence Owner

    Posted 11-06-2019 07:30 AM
    ​My experience is that the business is more focused on the day to day ops and truly lacks the focus and awareness of the risks, or they aren't going to raise risks up because 1) putting controls in place will cost them time and effort  2) They perceive that others will think less of their ability for not having the controls in place to begin with.
    There must be independence when assessing vendor risk to ensure not only the vendor's ability to meet requirements and perform the work to meet the needs of the company, but also to ensure that the business has proper oversight and controls in place to ensure the company meets regulatory expectations related to risk.
    Best of Luck!

    ------------------------------
    Jenn Wilkinson
    Vice President
    Strategic Vendor Management

    ------------------------------



  • 13.  RE: Due Diligence Owner

    Posted 11-06-2019 08:12 AM
    Thanks everyone for your feedback. You're confirming my opinions!​


  • 14.  RE: Due Diligence Owner

    This message was posted by a user wishing to remain anonymous
    Posted 11-07-2019 11:19 AM
    This message was posted by a user wishing to remain anonymous

    I am a VM Specialist. Pretty much the business unit notifies us that they want to work with a new vendor. We send them a form to complete and after we receive that we start to gather the DD documentation. Once received we review all documentation.


  • 15.  RE: Due Diligence Owner

    Posted 11-06-2019 10:26 AM
    As the Vendor Management Officer, I manage the due diligence. I am notified when the vendor relationship managers want to conduct business with a new vendor. The vendor relationship manager acts as a filter between myself and the new vendor. I will send the various due diligence requests and questionnaires to the vendor relationship manager to send to their vendor contact. In order for the process to move smoothly and swiftly, I have to manage the process completely.