Due Diligence and Ongoing Monitoring

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  • 1.  NPI

    This message was posted by a user wishing to remain anonymous
    Posted 07-22-2022 01:32 PM
    This message was posted by a user wishing to remain anonymous

    How Often should you perform Due Diligence on a vendor that is Non Critical, low risk, but does have access to NPI?  What due diligence documents should you request due to the fact they do have NPI access?


  • 2.  RE: NPI

    Posted 07-30-2022 09:57 AM

    I am curious about what specific NPI they have access to where they will still be low risk. In my understanding, Nonpublic Personal Information, or NPI, is a type of sensitive information created and defined by the Gramm-Leach Bliley Act (GLBA), which specifically regulates financial services institutions.

    NPI may include names, addresses, phone numbers, social security numbers, bank and credit card account numbers, credit or debit card purchases, court records from a consumer report, or any other consumer financial information that:

    • a consumer provides to a financial institution
    • results from a transaction or service performed for the consumer
    • is otherwise obtained by the financial institutions
    • NPI does not include information that has been made publicly available or widely distributed in the media or public government records

    In any case, accessing NPI requires that the vendor demonstrate appropriate information security and privacy controls. This means reviewing all their SOC2 Type2 Reports, Security Certifications, penetration testing, etc. They would also need to provide evidence that they comply with privacy regulations. So, they should have a privacy policy, evidence of compliance training for their employees, and disclose any regulatory findings/actions and litigation history (including pending litigation) for the last five years.

    As to how often that is up to you and your organization. Generally, vendors who can access NPI are not low risk; they are at least moderate risk. But it would be best to do at least an annual risk re-assessment and due diligence. I hope that is helpful, but I would love to hear from other members.




  • 3.  RE: NPI

    Posted 08-23-2022 09:19 PM
    Depends on How much NPI. Is the unauthorized disclosure of the NPI something that will get you in trouble? Likely.
    That said... Appraisers have access to NPI but they are licensed and contracts are clear on security requirements. 

    But Access to NPI isn't the same as hosting, processing and maintaining NPI... 
    Can you elaborate more?

    ------------------------------
    Bradley Martin

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  • 4.  RE: NPI

    This message was posted by a user wishing to remain anonymous
    Posted 08-31-2022 02:21 PM
    This message was posted by a user wishing to remain anonymous

    Would you include the Document Destruction, Document Storage, Check Printing Services, and Cloud File Transfer Systems as having NPI, since they have access to our customers NPI?

    Or am I misunderstanding the concept of access?

    Thanks


  • 5.  RE: NPI

    Posted 08-31-2022 02:41 PM
    If the vendor is processing (check printing), storing (document storage) or accessing NPI data (transferring data or destroying data) i would consider that as having access to NPI. You want to ensure that due diligence is in place to validate that vendor has adequate controls in place to protect that information.


  • 6.  RE: NPI

    This message was posted by a user wishing to remain anonymous
    Posted 09-01-2022 10:15 AM
    This message was posted by a user wishing to remain anonymous

    Currently we score a vendors with only access to NPI (Document Destruction, Document Storage, Check Printing Services) as a lower inherent risk score than vendors like our core vendor, who (Process, Store, Manage, View/Add/modify).

    Are we doing this correctly?



  • 7.  RE: NPI

    This message was posted by a user wishing to remain anonymous
    Posted 09-02-2022 08:33 AM
    This message was posted by a user wishing to remain anonymous

    For us, a vendor with NPI access by default is not low risk. They're usually either moderate or high risk depending upon the type of NPI they can access.