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    Service Provider

    Assessment FrameworkA Platform for Building Synergies between Clients and

    Service Providers for Trusted Global Sourcing

    A Study Report

    Data Security Council of India in collaboration with Ernst & Young

    December 2010

    Under Cyber Security Awareness Program,

    Department of Information Technology, Government of India

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    Data Security Council of India (DSCI) is a section 25, not-for-prot company, setup by NASSCOM as

    an independent Self Regulatory Organization (SRO) to promote data protection, develop security andprivacy codes & standards, and encourage the IT/BPO industry to implement the same.

    For more information about DSCI or this report, please contact:

    Data Security Council of India

    Niryat Bhawan, 3rd Floor, Rao Tula Ram Marg, New Delhi 110057, India

    Phone: +91-11-26155070

    Fax: +91-11-26155072

    Email: [email protected]

    2010 DSCI. All rights reserved.

    About DSCI

    DisclaimerThis document contains information that is Intellectual Property of DSCI.

    DSCI expressly disclaims to the maximum limit permissible by law, all

    warranties, express or implied, including, but not limiting to implied warranties

    of merchantability, tness for a particular purpose and non-infringement. DSCI

    disclaims responsibility for any loss, injury, liability or damage of any kind resulting

    from and arising out of use of this material/information or part thereof. Views

    expressed herein are views of DSCI and/or its respective authors and should not

    be construed as legal advice or legal opinion. Further, the general availability of

    information or part thereof does not intend to constitute legal advice or to create a

    Lawyer/ Attorney-Client relationship, in any manner whatsoever.

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    3

    Service Provider Assessment Framework

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    Service Provider Assessment Framework

    The IT (Amendment) Act, 2008 has established a strong data protection regime in the country,

    by requiring body corporates to implement reasonable security practices to protect sensitivepersonal information. What is reasonable security though? An organization is expected to have

    a comprehensive information security program, with appropriate controls that are commensurate

    with its information assets and risk assessment. In the event of a security breach, it should be able

    to demonstrate that its practices were in conformance with its written security policy, and that its

    controls were adequate. It is, however not that easy, since enterprises are outsourcing some of their

    work, and they must manage information risk across a vast global network of Service Providers.

    Outsourcing thus brings into focus the practices followed by Service Providers, and

    their accountability.

    Service Providers are subjected to ongoing assessments and on-site audits, which are labor-

    intensive and costly for both the sides. Likewise, Service Providers with hundreds of Clientsdistributed in various geographies must submit themselves to several audits by the Clients.

    Moreover, the multiple assessments are based on different frameworks, questionnaires and audit

    approaches clearly they result in wasted effort and time; and, of course, higher costs. It is the wish

    of both - Clients and Service Providers - that third-party evaluations that are standards-based, or

    framework-based, may ease the assessment burden. But how do they view the implementation of

    a standard, or best practices for security; and an assessment framework to validate that this has

    indeed made the organization secure? Again both of them will have a different perspective on this.

    Can enterprises take a methodical approach to assessing and managing the risks through

    frameworks like ISO 27001; BITS Shared Assessment Program, Moodys Vendor Information Risks

    ratings, Information Security Forum, COSO, NIST or COBIT? Will attestation of a Service Providerspractices necessarily be in the form of a third-party certication, or a maturity rating of its practices?

    Foreword

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    With DSCI best practices and data-centric methodology, weve rolled out a solution for adoption by

    Service Providers to make them secure. DSCI Security Framework (DSF) is based on a number ofsecurity principles, that help make the security program of an organization dynamic, instead of a static

    checklist approach that relies on bulky documentation. We wanted to review the available assessment

    frameworks, to see how DSF could t into them, and how rating of practices may give a sense of

    security to organizations, and also show them the direction for improvements. In short, itll help realize

    an effective security program, and transparent assessment framework, that may address the concerns

    of both Clients and Service Providers. In the process, reasonable security practices will

    get implemented.

    It is with this in view that DSCI partnered with Ernst & Young Pvt. Ltd. (EY) in this study, which required

    extensive knowledge and experience in the domain, to review the existing frameworks and think

    through the advantages of certication/ratings. Survey of Clients and Service Providers, based on anin-depth questionnaire gives key pointers to the concerns of both the groups, and points towards a

    possible third-party ratings approach that may be useful and acceptable to both, namely Clients and

    Service Providers.

    I would like to acknowledge the great team effort of DSCI and EY in conducting this study, and creating

    a useful analysis. I hope this report will generate sufcient interest among Clients, Service Providers,

    and even governments and regulators that will help DSCI arrive at the right decisions in taking the next

    steps in certication/rating of Service Providers.

    Kamlesh Bajaj

    CEO, DSCI

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    Service Provider Assessment Framework

    The study teamData Security Council of India

    Mr. Vinayak Godse Director Data Protection

    Mr. Vikram Asnani Senior Consultant Security Practices

    Mr. Rahul Jain Senior Consultant Security Practices

    Ernst & Young Pvt. Ltd.

    Ms. Nity Singh Manager Advisory Services

    Mr. Taslimm Quraishi Manager Advisory Services

    Mr. Lalit Kalra Consultant Advisory Services

    DSCI Project Advisory Group

    Prof. N. Balakrishnan Chairman DSCI and Associate Director, Indian Institute

    of Science (IISc), Bangalore

    Mr. B.J. Srinath Senior Director, Indian Computer Emergency Response

    Team (CERT-In)

    Prof. Anjali Kaushik Management Development Institute, Gurgaon

    Mr. Akhilesh Tuteja Executive Director, KPMG

    Mr. Kartik Shahani Country Manager, India & SAARC, RSA

    Mr. Satish Das CSO, CognizantMr. Baljinder Singh Global Head of Technology, Information Security &

    Business Continuity, EXL Service (I) Pvt. Ltd.

    Mr. Vishal Salvi CISO, HDFC Bank Pvt. Ltd.

    Mr. Ashwani Tikoo CIO, Computer Sciences Corporation India Pvt. Ltd.

    Mr. PVS Murthy Global Head Information Risk Management

    Advisory, TCS

    Mr. Deepak Rout CISO, Uninor

    Ms. Seema Bangera DGM Information Security, Intelenet Global

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    Service Provider Assessment Framework

    Executive summaryBusinesses today are global, complex and fast evolving, and technology has made

    business transactions independent of space and time. This has enabled businesses tofocus on its core competencies and outsource non-core business operations to Service

    Providers, who are capable of providing services to the businesses from around the

    world round the clock. Information Security and Privacy becomes crucial when it comes

    to outsourcing as technology enables free ow of information across borders between

    Clients and Service Providers. This information could be business sensitive information

    and / or sensitive personal information of the Clients end customers including but not

    limited to health related information, credit card details, social security number, etc.

    Also, stringent global data protection regulations make the businesses liable for loss,

    misuse, wrongful disclosure of any personal information of any citizen irrespective

    whether the failure is at outsourcers end or Service Providers end.

    The Indian IT/BPO Service Providers are striving hard to ensure that security and

    privacy of data is well maintained. They follow stringent security controls specied by

    the Clients through contractual obligations. The Clients conduct regular Information

    Security and Privacy assessments of the Service Providers to ensure compliance

    with the contractual obligations and / or regulatory requirements or to simply assess

    the security posture of Service Providers. In this outsourcing ecosystem, many

    Clients have developed and applied their own proprietary assessment frameworks for

    evaluating their Service Providers. Service Providers, on the other hand, strain their

    resources to respond to diverse client information requests. This isolated approach

    proves to be an inefcient and costly affair, both for the Clients and the Service

    Providers. Inconsistencies arising from use of different assessment methodologies

    cause delays, resulting in inefcient use of time and resources. Aggravating the

    problem is the unavailability of generally accepted standard for Service Provider

    assessments. To overcome these issues and challenges, DSCI as an industry initiative

    seeks to establish a well dened Service Provider Assessment Framework in order to

    have a common assessment approach that can be used to assess different

    Service Providers.

    This study especially through its survey attempts to understand the perspective of

    Client and Service Provider organizations with respect to Service Provider assessments

    and takes inputs to dene a Service Provider Assessment Framework.

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    Service Provider Assessment Framework

    The survey results reveal that:

    DSCI should play a vital role in conducting Service Provider assessments and sharingthe outcome in the ecosystem. It should:

    have an Service Provider assessment program that comprises of framework, processes,

    and methodology for assessments

    provide an organization wide security and privacy maturity rating, and domain specic

    maturity rating that may be shared in the ecosystem after taking the due permission of the

    Service Providers

    A new standard mapped to prevalent standards should be considered as a potential

    assessment standard for third party assessments of Service Providers

    DSCI as an industry initiative and a Self Regulatory Organization having

    representation from both the Client and Service Provider organizations should

    empanel auditing rms for conducting independent third party assessments of

    Service Providers

    The study also focused on understanding of various assessment models which included

    Malcolm Baldrige Framework, Capability Maturity Model Integration (CMMI), CRISIL

    Ratings, BITS framework, e-Sourcing Capability Model (eSCM), Moodys assessment

    framework. The study of assessment models reveals that:

    Service Provider Assessment Framework should be easy to comprehend and

    adaptable regardless of size of the organization and nature/ complexity of its

    processes

    The framework assessment areas should be outlined in the form of best practices

    rather than a stringent set of controls. This would provide an opportunity to

    organizations for implementing / performing the control activities according to the

    needs of the organization specic environment

    The framework should follow a process-approach and outline measurable

    assessment areas

    It should be reviewed and updated (if required) on a periodic basis

    The maturity criteria should be transparent, and should help in assigning a formal

    maturity rating to a Service Provider

    Overall, DSCI may develop a Service Provider Assessment Framework that is aligned

    to DSF Best Practices & the maturity criteria dened for each of its sixteen security

    disciplines and the study results elucidated in this report; and make it popular in the

    ecosystem by performing pilot runs. The framework may follow a CMMI-like rating

    methodology which is assessment of the security and privacy practices at both the

    layers capability/ maturity of the business processes, and maturity of the organization.

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    Introduction.................................................................................................................. 1Survey Highlights......................................................................................................... 5

    Detailed Survey Results ...............................................................................................7

    Key drivers for Service Provider assessments....................................................7

    Scale of Service Provider assessments.............................................................. 9

    Current assessment program/ mechanism ....................................................... 11

    Focus on Data Privacy in Service Provider assessments .................................13

    Types of Service Provider assessments ........................................................... 14

    Level of perceived risk IT services .................................................................15

    Level of perceived risk BPO services .............................................................17

    Risk proling of Service Providers..................................................................... 18

    Frequency of Service Provider assessments ....................................................19

    Budget and cost for Service Provider assessments..........................................21

    Modes of Service Provider assessments ..........................................................23

    Service Provider assessment challenges..........................................................25

    Service Provider assessments solutions and future landscape .....................27

    Inuence of IT (Amendment) Act, 2008 on Service Provider assessments ......29

    Third party assessments ...................................................................................31

    Third party assessors ........................................................................................33

    Standards for Service Provider assessments ...................................................35

    Role of DSCI in Service Provider assessments ................................................37

    Outcome of Service Provider assessments ......................................................39

    Sharing of Service Provider assessment results...............................................41

    Recommendations......................................................................................................43

    Annexure .................................................................................................................... 45

    Glossary .....................................................................................................................57

    References .................................................................................................................57

    Content

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    1

    Service Provider Assessment Framework

    Background

    As buyers of Information Technology (IT) and Business Process

    Outsourcing (BPO) services become increasingly sophisticated

    and demanding, Service Providers are challenged to achieve

    new levels of efciency, agility and transparency in service

    delivery and protection of information. Clients increasingly

    expect real evidence of robust process management, continuous

    improvement, effective governance, and measures adopted for

    ensuring Information Security and Privacy.

    Objective

    DSCI engaged EY to study the current landscape of Service

    Provider (IT/BPO organizations) assessments conducted by the

    Client organizations, and assist in documenting the assessment

    approach that may be adopted in order to minimize the challenges

    of both, Client and Service Provider organizations, with an intent

    of evaluating and reporting on Information Security and Privacy

    posture of the Service Providers.

    Approach

    In order to achieve the project objectives, the joint study team

    undertook the following steps:

    Primary research : A survey of Client and Service Provider

    organizations was undertaken to gain an insight into the currentService Provider assessment program. The survey covered the

    following aspects:

    Business drivers for Client organizations to conduct Service

    Provider Assessments

    Introduction

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    2

    The value that various Service Provider assessments conducted by

    Client organizations bring to the Service Providers

    Investments made, and challenges faced by the Service Provider

    and Client organizations in driving such assessments

    Possible solutions for overcoming the current challenges

    Role of DSCI and third parties in Service Provider assessments

    Secondary research : A study was undertaken to document

    the pros and cons of prevalent assessment frameworks likeCapability Maturity Model Integration (CMMI), BITS sharedassessment program, Carnegie Mellon University e-Sourcing

    Capability Model (eSCM), etc. The list of assessment frameworkswas documented on the basis their widespread use, and

    international recognition in performing assessments. The studyareas included the following:

    Assessment areas / ease of use by the organization being

    assessed

    Assessment methodology / scoring pattern / process of sharing

    assessment results

    Acceptability / popularity of the framework

    Independence of examiners

    Frequency of framework update to cater to future requirements

    The team also studied DSCI Security Framework (DSF)

    Best Practices and maturity rating criteria for each of its sixteen

    disciplines to gather inputs (in addition to the inputs provided by

    primary and secondary research) for dening Service Provider

    Assessment Framework.

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    3

    Service Provider Assessment Framework

    Prole of participantsThe survey respondents were a set of Client and Service

    Provider organizations. The respondents were majorly from

    Information Technology (IT), Business Process Outsourcing (BPO),

    Telecommunications and Financial Services verticals. Correspondingly,

    the survey results have been divided into two perspectives Clients

    perspective and Service Providers perspective, and may be

    read accordingly.

    Industry wise distribution

    KPOBPO IT Services

    42.00%

    50.00%

    8.00%

    Client organizations

    Service Provider organizations

    37.00%

    18.00%

    36.00%

    9.00%

    Industry wise distribution

    Telecommunication Banking

    Technology Financial Services

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    4

    Service Provider Assessment Framework

    6$ 1 billion to $ 9 billion

    4$ 100 million to $ 249 million

    1$ 10 billion to $ 24 billion

    1Less than $ 100 million

    Number of Service Providers

    Number of Client organizations

    3

    3

    1

    2

    More than $ 24 billion

    $ 1 billion to $ 24 billion

    $ 100 million to $ 249 million

    Less than $ 100 million

    Client organizations

    Service Provider organizations

    The sample size selected for the survey was limited and this should betaken into consideration when interpreting the survey results.

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    5

    Service Provider Assessment Framework

    Service Provider assessments are conducted by Client organizationsin order to protect business sensitive information, and mitigate security

    & privacy risks while outsourcing work to Indian IT/ BPO companies.These assessments help Service Provider organizations to align

    security & privacy initiatives to their Clients requirements and build onthe existing relationship with the Clients

    Comprehensive risk based assessments covering all the domains ofsecurity are carried out annually by majority of Client organizations.

    Vulnerability assessments and penetration testing continue to display

    strong acceptance (100%) by Client organizations in Service Providerassessment programs

    Most of the Service Provider organizations reported that ISO 27001controls checklist is used as a mechanism by their Clients for

    conducting assessments. On the other hand, Client organizationsrevealed that a proprietary Service Provider assessment program has

    been developed to conduct Service Provider assessments

    Provisions of the IT (Amendment) Act, 2008 (ITAA 2008) need to beappropriately incorporated in the Client-Service Provider contracts

    High number of assessments around the year is the most critical

    challenge faced by Service Providers at the time of assessments,followed by meeting diverse & varied assessment. Whereas for

    Clients, rising legal liabilities, regulatory requirements, level of securityawareness in the Service Providers, ensuring compliance by Service

    Providers, and Service Provider commitment to ensure InformationSecurity & Privacy are some of the critical challenges faced in

    assessing Service Providers

    Survey highlights

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    6

    Currently, Service Provider assessments are majorly conductedonsite by Clients internal staff. Majority of the Client organizations

    indicated that auditing rms empanelled by a joint industry consortiumof outsourcers and the Service Providers could act as the third party

    assessors for conducting independent Service Provider assessments

    More than half of the Service Provider respondents suggested thatDSCI should have a Service Provider assessment program that

    comprises of framework, processes, methodology for assessments

    Clients and Service Providers reveal that third parties should conductService Provider assessments, based on a standardized assessmentmethodology. This would save costs and efforts by avoiding the need

    for conducting assessments of multiples Service Providers

    Both Client and Service Provider respondents suggested a newstandard mapped to ISO 27001, NIST SP, COBIT, ITIL etc. that meets

    all the regulatory requirements like GLBA, HIPAA, PCI DSS etc., as apotential assessment standard for third party assessments of

    Service Providers

    DSCI should provide organization wide security and privacy maturityrating, and also domain specic maturity rating

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    7

    Service Provider Assessment Framework

    Key drivers for Service Provider assessments

    The survey results reect that majority of the Clients consider

    protecting business sensitive information, and mitigating security

    & privacy risks as the critical business drivers for conducting

    Service Provider assessments. On the other hand, Service

    Providers report that Clients corporate policy requirements, and

    achieving end customer condence are the main reasons which

    drive their Clients to conduct assessments.

    Detailed survey

    results

    Clients perspective

    Business drivers for conducting Service Provider assessments

    88.89%

    88.89%

    77.78%

    77.78%

    55.55%

    44.44%

    33.33%

    Protecting business sensitive information including

    intellectual property

    Mitigating security and privacy risks that exist in

    outsourcing arrangements

    To address the security and privacy concerns of

    some of the key stakeholders within our organization

    Strengthening of data protection regime in the

    geographies where we operate, stipulating stringent

    requirements and heavy fines for a data breach

    Use Service Provider assessments as a mechanism to

    foster a culture of compliance at all Service Providers and

    introducing a sense of competition among them with regards

    to fulfillment of their data security and data privacy needs

    Addressing security and privacy risks that arise

    from use of emerging technologies

    Data protection regulations demand our

    organization to undertake regular assessments of

    third parties

    44.44%Our corporate policies require us to undertake a

    comprehensive vendor risk assessment

    Achieving end customer confidence and preventing

    loss of reputation by mitigating risks of privacy/

    information leakage that may arise at Service Provider end

    55.55%

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    8

    Service Provider assessment as a mechanism to foster a culture

    of compliance was selected by the least number (thirty three

    percent) of Clients while the same response was selected by fty

    percent of the Service Provider organizations, as a reason for

    conducting assessments.

    Reasons that drive Clients to conduct Service Provider assessments

    66.67%

    66.67%

    58.33%

    58.33%

    50.00%

    50.00%

    41.67%

    41.67%To address the security and privacy concerns of

    some of the key stakeholders in Client organization

    Protecting business sensitive information including

    intellectual property

    Clients use Service Provider assessments as a mechanism

    to foster a culture of compliance at all its Service Providers

    and introducing a sense of competition among them with

    regards to fulfillment of their data security and data privacy needs

    Clients corporate policies require them to

    undertake a comprehensive vendor risk assessment

    Achieving end customer confidence and preventing

    loss of reputation by mitigating risks of privacy/

    information leakage that may arise at Service Provider end

    Mitigating security and privacy risks that exist in

    outsourcing arrangements

    Data protection regulations demand Client organization

    to undertake regular assessments of third parties.

    Strengthening of data protection regime in the

    Client geographies that stipulate stringent

    requirements and heavy fines for a data breach

    Service Providers perspective

    Protecting business

    sensitive information

    and mitigating security

    and privacy risks are

    the major drivers for

    conducting Service

    Provider assessments

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    9

    Service Provider Assessment Framework

    Scale of Service Provider assessmentsThe survey results show that the number of Service Provider

    assessments is directly proportional to the number of Clients or Service

    Providers that an organization is engaged with. This is proven by the

    fact that Clients working with 500 Service Providers conduct more

    than 100 Service Provider assessments annually, and those with 200

    & 300 Service Providers conduct 10-50 and 50-100 Service Provider

    assessments respectively. Also, Service Providers engaged with 800

    Clients undergo 100-200 assessments annually, and those with 700 &

    600 Clients undergo 50-100 assessments respectively 50-100

    assessments respectively.

    Number of Service Providers the organization is engaged with

    0

    100

    200

    300

    400

    500

    600

    1 2 3 4 5 6 7 8 9

    Numberof

    S

    eviceProviders

    Clients

    11.11%0-5

    22.22%5-10

    44.44%10-50

    Number of Service Provider assessments conducted

    11.11%

    11.11%Above 100

    um

    ero

    annualassessments

    50-100

    Clients perspective

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    Service Provider Assessment Framework

    Service Providers perspective

    Number of Clients serviced by the organization

    0

    100

    200

    300

    400

    500

    600

    700

    800

    900

    1 2 3 4 5 6 7 8 9 10 11 12

    NumberofClients

    Service Providers

    Number of Service Provider assessments faced

    9.09%

    Numberofan

    nualassessments

    36.36%50-100

    Above 400

    27.27%200-400

    9.09%100-200

    18.18%10-50

    0.00%0-10

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    11

    Service Provider Assessment Framework

    Current assessment program/ mechanismProprietary Service Provider assessments followed by SAS 70 and ISO

    27001 checklist are the most commonly adopted assessment programs/

    mechanisms by Client organizations.

    On the other hand, more than ninety percent Service Providers reported

    that their Clients use ISO 27001 checklist for conducting assessments.

    This is closely followed by proprietary assessment programs and

    assessment programs of Client appointed external auditors (sixty seven

    percent each).

    The survey further revealed that majority of the Client organizationsdo not consider ISO 27001 certication as an alternative to conducting

    Service Provider assessments.

    Interestingly, the survey also highlighted that BITS Shared Assessment

    Program is not used by any of the Client organizations for conducting

    Service Provider assessments.

    77.78%

    44.44%

    44.44%

    33.33%

    22.22%

    22.22%

    11.11%

    0.00%

    ISO 27001 controls checklist

    BITS shared assessment program

    Assessment program developed by our

    organization (proprietary)

    Reliance on Statement on Auditing Standards

    (SAS) No. 70 report provided by the auditing

    firm assessing your Service Providers

    Asking the Service Providers to get ISO 27001

    certified thereby eliminating the need for

    getting assessed

    Use pre-defined controls list provided by an

    assessment tool

    Asking the Service Providers to provide self

    declaration/attestation for compliance to oursecurity policies/requirements

    Assessment program of the appointedexternal auditor

    Service Provider assessment program/mechanism used by the organization

    Clients perspective

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    12

    Service Provider Assessment Framework

    78% Clientorganizations use

    proprietary assessment

    programs for conducting

    Service Provider

    assessments. However,

    the Service Providers

    report that their

    Clients use ISO 27001

    checklist for conducting

    security and privacy

    assessments

    Programs / mechanisms used by Clients for conducting assessments

    91.67%

    66.67%

    66.67%

    41.67%

    25.00%

    16.67%

    16.67%

    0.00%

    ISO 27001 controls checklist

    BITS shared assessment program

    Others

    Use pre-defined controls list provided by

    an assessment tool

    Providing self declaration / attestation forcompliance to client security policies/

    requirements

    Getting ISO 27001 certification

    eliminates the need for getting assessed

    Assessment program of the client

    appointed external auditor

    Assessment program developed by the

    client (proprietary)

    Service Providers perspective

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    13

    Service Provider Assessment Framework

    Focus on Data Privacy in Service Provider assessmentsThe survey reveals that majority of the Client organizations cover

    privacy during Service Provider assessments. Contrastingly, majority

    of the Service Providers report that privacy is not covered as part of

    the assessments.

    Eleven percent of the Client organizations also revealed that privacy

    is not covered as part of Service Provider assessments. Also, Client

    organizations seem to be satised with the current focus on privacy as

    no Clients foresee the need for a change in the privacy focus in Service

    Provider assessment programs.

    Privacy is not covered

    11.00%

    56.00%33.00%

    Coverage of privacy in Service Provider assessments

    Strongly

    Moderately Needs improvement (0%)

    Coverage of privacy in Service Provider assessments

    41.67%

    25.00%

    33.33%

    Minority of clients Service Providers

    assessment programs cover PrivacyMajority of clients Service Providers

    assessment programs cover Privacy

    Nearly half of the clients assessment

    programs cover Privacy

    None of the clients Service Provider

    assessment programs cover Privacy (0%)

    Clients perspective

    Service Providers perspective

    Majority of the Service

    Providers report that

    their Clients do not

    cover Privacy during

    assessments while

    Clients stronglyperpetuate the coverage

    of Privacy in Service

    Provider assessments

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    Service Provider Assessment Framework

    Clients perspective

    Service Providers perspective

    Types of Service Provider assessmentsVulnerability Assessment and Penetration Testing as a methodology of

    Service Provider assessments has a strong acceptance (100%) from

    Client organizations.

    While only twenty ve percent of Service Providers reveal line of service

    specic assessments is considered important by

    their Clients, Client organizations give more importance to

    these assessments.

    Service Providers reveal that

    Client organizations display

    a strong propensity towards

    undertaking comprehensive

    risk-based assessments,

    and compliance basedassessments

    Different types of Service Provider assessments conducted by

    the organization

    100.00%

    88.89%

    77.78%

    77.78%

    Risk based assessments

    Lines of Service specific assessment (e.g.

    conducting application security assessment forapplication development services)

    Technical: vulnerability assessment and

    penetration testing

    Regulatory / Compliance: Assessments to check

    compliance with applicable regulations (e.g. HIPAA,

    GLBA) or Assessments based on compliance to

    Standards like ISO 27001 and PCI DSS

    Different types of assessments conducted by Client organizations

    100.00%

    83.33%

    75.00%

    75.00%

    25.00%

    Comprehensive risk based assessmentcovering all the domains of security

    Assessment based on well-known

    standards like ISO 27001

    Comprehensive compliance based

    assessment

    Line of Service specific assessment (e.g.

    conducting application security assessment for

    application development services)

    Technical assessment of the IT systems including

    vulnerability assessment and penetration testing

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    15

    Service Provider Assessment Framework

    Level of perceived risk IT servicesResults indicate that Client organizations perceive that outsourcing

    Custom Application Development services (seventy eight percent)

    involves high risk. This is distantly followed by Infrastructure, Network

    and Desktop Outsourcing and Software Deployment and Support at

    sixty seven percent each.

    Service Providers cited Infrastructure Outsourcing followed by Network

    and Desktop Outsourcing as the critical risk areas for Service Provider

    assessments.

    Clients as well as Service Provider organizations do not attachimportance to IT Education and training services for assessments.

    33.33% 11.11% 33.33%Hardware deployment and support

    Level of perceived risks in the services outsourced by

    Client organizations: IT services

    High Medium Low

    77.78% 11.11%Custom application development

    55.56% 33.33%Application management

    66.67% 11.11% 11.11%Infrastructure services outsourcing

    66.67% 11.11% 11.11%Software deployment and support

    44.44% 22.22% 22.22%System integration

    44.44% 44.44%Software testing

    66.67% 22.22%Network and desktop outsourcing

    44.44% 33.33%Hosted application management

    44.44% 33.33%Hosted infrastructure services

    33.33% 22.22% 22.22%Network consulting and integration

    11.11% 22.22% 44.44%IT education and training

    22.22% 22.22% 33.33%IT consulting

    Custom Application

    Development,

    Network and Desktop

    Outsourcing together

    with Infrastructure

    outsourcing are currentwatchwords in the

    context of Service

    Provider assessments

    Clients perspective

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    41.67%

    33.33%

    25.00%

    25.00%

    25.00%

    16.67%

    8.33%

    8.33%

    8.33%

    16.67%

    8.33%

    33.33%

    8.33%

    16.67%

    8.33%

    Infrastructure services outsourcing

    Level of perceived risks in the services outsourced by Client

    organizations: IT services

    Network and desktop outsourcing

    Application management

    Hosted application management

    Hosted infrastructure services

    System integration

    Software testing

    Custom application development

    8.33% 16.67%Software deployment and support

    8.33% 16.67%Hardware deployment and support

    16.67% 8.33%Network consulting and integration

    8.33% 16.67%IT education and training

    16.67% 8.33%IT consulting

    High Medium Low

    Service Providers perspective

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    Level of perceived risk BPO servicesThe survey results indicate that sixty seven percent of Client

    organizations and forty two percent of Service Provider organizations

    consider that Finance and Accounting services involve high risk.

    66.67% 11.11%Finance and accounting

    44.44% 22.22%Customer interaction and support

    44.44% 33.33% 11.11%Human resource management

    44.44% 22.22% 11.11%Knowledge services

    44.44% 22.22% 11.11%Vertical specific BPO services

    22.22% 33.33% 11.11%Procurement services

    High Medium

    Level of perceived risks in the service outsourced by Client

    organizations: BPO services

    Low

    41.67%

    25.00%

    25.00%

    25.00%

    16.67%

    8.33%

    8.33%

    8.33%

    16.67%

    16.67%

    8.33%

    8.33%

    8.33%

    8.33%

    Finance and accounting

    Level of perceived risks in the service outsourced by Client

    organizations: BPO services

    Customer interaction and support

    Human resource management

    Knowledge services

    Vertical specific BPO services

    Procurement services

    High Medium Low

    Clients perspective

    Service Providers perspective

    Finance and Accounting

    services are considered

    important by majority

    of the organizations in

    the context of Service

    Provider assessments

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    Service Provider Assessment Framework

    Clients perspective

    Risk proling of Service ProvidersThe growing awareness of the risk management in the Indian IT/

    BPO industry was clearly evident from the survey, which displayed

    that almost ninety percent of the Client organizations undertake a risk

    proling for their Service Providers.

    The survey results also emphasize the importance of Information

    Security and Privacy with nature and criticality of the business

    outsourced along with sensitivity of the data exported to Service

    Providers being given the most important criterion for risk proling.

    Undertake risk profilingDo not undertake risk profiling

    11.00%

    89.00%

    88.89%

    88.89%

    88.89%

    66.67%

    55.56%

    44.44%

    44.44%

    Sensitivity of data exported to the Service Providers

    Type of connectivity with the Service Providers

    Dependency on the Service Providers

    Size and maturity of the Service Providers

    ISMS certification achieved by the Service Providers

    Nature & criticality of the business/

    services outsourced

    Security incidents/breaches in the past

    Criteria used for risk profiling of Service Providers

    89% of the Client

    organizations relyon risk proling to

    determine the frequency

    of Service Provider

    assessments

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    Service Provider Assessment Framework

    Frequency of Service Provider assessmentsThe fact established in the previous question gets reestablished

    by the frequency of Service Provider assessments undertaken by

    Client organizations that perform risk proling; the survey results

    show that the Service Providers identied under critical risk

    category undergo quarterly assessments.

    A similar trend is observed for the Service Providers identied

    under Medium and Low risk categories, undergoing half

    yearly and yearly assessments by fty six and forty ve percent

    respondents respectively.

    Organizations that do not undertake risk proling, yearly

    assessments are preferred by almost twenty three percent of the

    organizations. Also eleven percent of Client organizations believe

    that the frequency depends on the trust and relationship between

    Client and Service Providers.

    Frequency of assessing the Service Providers

    33.33%

    22.22%

    11.11%

    22.22%

    55.56%

    22.22%

    11.11%

    22.22%

    22.22%

    11.11%

    44.44%

    33.33%

    Critical risk

    High risk

    Medium risk

    Low risk

    Negligible

    Quarterly Half yearly Yearly

    Clients perspective

    The Service Providers

    with critical risk undergo

    quarterly assessments

    as per thirty three

    percent of Client

    organizations

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    Clients perspective

    The cost of periodic

    Service Provider

    assessments is built into

    the service delivery cost

    of Service Providers,

    and is a part of the

    contractual terms

    Budget and cost for Service Provider assessmentsThis question was aimed at identifying the cost impact of Service

    Provider assessments on Clients and Service Providers.

    Results highlight that majority of the Client organizations allocate only

    a small portion of IT security budget for Service Provider assessments.

    Only one of the respondents indicated that the organization

    allocates signicant portion of IT security budget for Service Provider

    assessments. On the other hand, majority of the Service Providers

    allocate a considerable portion of the IT security budget towards

    assessments. This is because the cost for periodic Service Provider

    assessments is built into the service delivery cost of Service Providersand is part of the contract with the Service Providers.

    Service Provider respondents in the Others category indicated that cost

    of the assessment could be borne by either party, and it depends on the

    relationship and understanding between the Client and the

    Service Provider.

    Portion of the IT security budget allocated for conducting Service

    Provider assessments

    44.44%

    22.22%

    22.22%

    11.11%

    Small

    Considerable

    Negligible

    Significant

    Cost of Service Provider assessments

    55.56%

    44.44%

    22.22%

    22.22%

    11.11%

    11.11%

    11.11%The cost is borne at the time of the Service

    Provider assessments by the Service Provider

    Efforts spent by the Service Provider resources

    in coordinating / facing the assessments are

    billed by the Service Providers

    Significant cost of the Service Provider assessments

    comprises of overhead expenses like travel, etc

    for our assessors

    The cost is borne at the time of the Service

    Provider assessments and is shared between

    Client and Service Provider as per the contract

    The cost is borne at the time of the Service

    Provider assessments by the Client

    We allocate a portion of our IT security budget

    for conducting Service Provider assessments

    The cost for periodic Service Provider assessments

    is a part of the contract

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    Portion of IT security budget allocated for facing assessments

    66.67%

    25.00%

    8.33%

    0.00%

    Considerable

    Small

    Significant

    Negligible

    Cost of Service Provider assessments

    66.67%

    33.33%

    33.33%

    25.00%

    16.67%

    8.33%

    8.33%

    16.67%Others

    The cost for periodic Service Provider assessments is a

    part of the contract

    The cost is borne at the time of the Service Provider

    assessments by the Client

    Efforts spent on Service Provider assessments

    is billed to the clients

    The cost is borne at the time of the Service Provider

    assessments and is shared between Client and Service

    Provider as per the contractThe cost is borne at the time of the Service Provider

    assessments by the Service Provider

    Significant cost of the assessments comprises of

    overhead expenses like travel,and stay arrangements

    for clients and/ or their sourced assessors

    We allocate a portion of our IT security budget for

    Service Provider assessments

    Service Providers perspective

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    Modes of Service Provider assessmentsClient organizations prefer conducting onsite assessments post a

    self assessment by the Service Provider organizations either by

    their internal staff or by sourced assessors.

    The survey results highlight that higher the risk perceived during

    risk proling, more is the focus on assessments. Majority of the

    respondents conduct onsite assessments for critical, high and

    medium risk Service Providers. For low risk category of Service

    Providers, majority of the Client organizations adopt offshore self

    assessments.

    Client organizations that do not perform the risk proling of their

    Service Providers prefer to undertake onsite assessment by

    sourced assessors from auditing rms.

    Type Self

    Assessment(offshore)

    Telephonic

    (offshore)

    Onsite

    by OrgInternal

    staff

    Onsite by org

    internal staffand sourced

    assessors

    from auditing

    rms

    Onsite by

    sourcedassessors

    Third Party

    AssessmentsCategory

    Critical risk 2 2 6 4 3 3

    High risk 2 2 6 3 4 3

    Medium risk 4 2 6 3 1 2

    Low risk 5 3 4 1 0 0

    Negligible 3 2 4 1 0 0

    Clients perspective

    *For Client organizations that undertake risk proling of

    Service Providers

    *This data table is for eight Clients. Eight out of nine Clients interviewed undertake risk proling.

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    Service Provider Assessment Framework

    Modes adopted by Clients for conducting Service Provider assessments

    100.00%

    75.00%

    66.67%

    66.67%

    25.00%

    25.00%

    8.33%

    8.33%

    Onsite assessments are conducted by

    clients internal staff

    Onsite assessments are conducted by

    sourced assessors

    Onsite assessments are conducted by

    an independent Third party

    Telephonic assessments are conducted by

    sourced assessors hired by client organization

    Telephonic assessments are conductedby clients internal staff

    Self assessment questionnaire are provided in

    an assessment tool available online; we directly

    upload our responses and evidences in

    the tool without any intervention of the client

    Onsite assessments jointly conducted

    by sourced assessors and clients internal staff

    Self assessment questionnaire are sent through

    email and we revert with the filled questionnaire and

    evidences without any intervention of the client

    Service Providers perspective

    Onsite assessments byClients internal staff or

    sourced assessors is

    the preferred mode of

    assessment by Clients

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    Service Provider Assessment Framework

    Service Provider assessment challengesThe survey results provide insight into the factors that inuence

    Information Security and Privacy assessments in IT/BPO organizations.

    Subcontracting by Service Providers and comfort provided by

    certications like ISO 27001 are the critical challenges faced by Client

    organizations in assessing Service Providers on Information Security &

    Privacy according to forty four percent of Client organizations. This is

    one of the reasons why Client organizations do not consider ISO 27001

    certication as an alternative to Service Provider assessments.

    44.44%

    44.44%

    33.33%

    22.22%

    22.22%

    22.22%

    22.22%

    22.22%

    11.11%

    11.11%

    11.11%

    11.11%

    11.11%

    11.11%

    11.11%

    33.33%

    11.11%

    33.33%

    44.44%

    33.33%

    55.56%

    22.22%

    55.56%

    44.44%

    22.22%

    22.22%

    22.22%

    22.22%

    33.33%

    55.56%

    44.44%

    44.44%

    11.11%

    44.44%

    22.22%

    11.11%

    33.33%

    55.56%

    11.11%

    22.22%

    55.56%

    55.56%

    44.44%

    55.56%

    44.44%

    11.11%

    44.44%

    44.44%

    Comfort/ assurance provided by

    certifications like ISO 27001

    Challenges faced by Client organizations

    Subcontracting by the Service Providers

    Inadequate budget

    Auditor accreditation and

    Auditors management

    Service Provider commitment

    Meeting multiple customer requirements

    Quantum of assessments

    Rising legal liabilities/

    regulatory requirements

    Level of security awareness in

    the Service Providers

    Ensuring compliance by your

    Service Provider

    Sensitizing key resources of

    Service Providers

    High direct and indirect costs

    Nature of outsourced work

    Tracking and closure of

    assessment findings

    High Medium Low

    Adoption of Non standardized Information

    Security and Privacy framework

    Availability of skilled resources forconducting the assessments

    Multiple Service Providers for differentlines of services in multiple geographies

    Clients perspective

    Subcontracting by

    the Service Providersand comfort provided

    by certications like

    ISO 27001 are most

    signicant assessment

    challenges faced by

    Client organizations

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    Service Providers perspective

    Factors such as cost, quantum of assessments were the least importantchallenges as perceived by Client organizations. Whereas, majority of

    Service Providers perceive high number of assessments around the

    year as one of the most signicant challenges.

    This difference in opinion regarding the challenges faced by Client

    and Service Provider organizations clearly indicates development of a

    robust assessment solution that meets the requirements of both parties.

    50.00%

    33.33%

    33.33%

    25.00%

    16.67%

    8.33%

    33.33%

    41.67%

    25.00%

    50.00%

    33.33%

    8.33%

    8.33%

    33.33%

    33.33%

    16.67%

    25.00%

    High number of assessments around the year

    High Medium Low

    Meeting diverse and varied assessment

    requirements of different clients

    Closing the findings by providing evidences and

    satisfying the client / auditors

    High direct and indirect costs associated with

    getting assessed multiple times

    Ensuring availability of time and resources for

    coordinating/facing the assessments

    Aligning to different areas of assessment/assessment methodologies adopted by

    different clients High number of

    assessments around

    the year, and meeting

    diverse Client

    requirements are critical

    challenges faced by

    most of the Service

    Providers

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    Service Provider Assessment Framework

    Service Provider assessments solutions andfuture landscape

    An attempt was made to identify the possible solutions for the

    challenges faced by organizations. The survey results reveal that

    approximately thirty three percent of Clients and forty two percent of

    Service Provider organizations prefer the development and adoption of

    an international standard for Service Provider assessment. Also, usage

    of BITS shared assessment program was selected by forty four Client

    Organizations as a rst preference among solutions.

    Results indicate that more than forty percent of Service Providers regard

    development and adoption of an internal standard as a rst preference.Independent third party assessments conducted by Self Regulatory

    Organizations (SRO) promoted by the Service Providers tops the chart

    for Service Providers as a second preference.

    Clients perspective

    Possible solution to overcome identified challenges

    44.00%

    33.00%

    22.00%

    22.00%

    11.00%

    11.00%

    11.00%

    11.00%

    33.00%

    22.00%

    11.00%

    11.00%

    11.00%

    11.00%

    First reference Second preference Third preference

    Industry & Service Provider promoted and

    standardized third party assessmentprograms like BITS

    Development and adoption of international

    standards for Service Provider

    Assessment

    There is no need for Service Provider

    assessments as data security and privacy

    risks are already addressed through contracts

    Self declaration by Service Providers for complying /

    fulfilling clients security requirements, therebymaking them liable for any security incident/data

    breach / violation shoul d suffi ce

    ISO 27001 certification should be accepted globally

    as a seal of trust and assurance; eliminating

    the need for Service Provider assessments

    Independent third party assessments

    conducted by Self Regulatory

    Organizations (SRO) promoted by the

    Service Providers

    As per Client

    organizations,industry and Service

    Provider promoted and

    standardized third party

    assessment program can

    be used for assessments.

    This is closely followed

    by development

    and adoption of an

    international standard

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    Development and

    adoption of an

    international standard

    is the rst preferencechosen by Service

    Providers

    Possible solution to overcome identified challenges

    41.67%

    33.33%

    25.00%

    8.33%

    8.33%

    0.00%

    8.33%

    25.00%

    8.33%

    41.67%

    25.00%

    8.33%

    8.33%

    33.33%

    8.33%

    16.67%

    First preference Second preference Third preference

    Development and adoption of international

    standards for Service Provider assessment

    ISO 27001 certification should be accepted by all

    the clients globally as a seal of trust and

    assurance; eliminating the need for Service

    Provider assessments

    Industry & Service Provider promoted and

    standardized third party assessment programs

    like BITS

    Independent Third Party assessments conducted

    by Self Regulatory Organizations (SRO)

    promoted by the Service Providers

    There is no need for Service Provider

    assessments as data security and privacy risks

    are already addressed through contracts

    Self declaration by Service Providers for complying/

    fulfilling clients security requirements, thereby

    making them liable for any security incident/

    data breach/violation should suffice

    Service Providers perspective

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    Inuence of IT (Amendment) Act, 2008 on ServiceProvider assessments

    There is widespread awareness about IT (Amendment) Act, 2008

    in the industry.

    More than fty percent of Service Provider and thirty three percent

    of Client organizations report that IT (Amendment) Act, 2008 will

    assist in strengthening the data protection initiatives of Indian

    Service Providers, and would provide greater assurance to the

    Clients. Approximately thirty three percent of Client organizations

    believe that IT (Amendment) Act, 2008 will have no impact on

    their Information Security and Privacy needs as they need tocomply with their countrys regulations outside of India.

    A similar number of Service Provider organizations revealed that

    they were not sure about the impact/ inuence of IT (Amendment)

    Act, 2008 on Clients assessment strategy.

    Influence of IT (Amendment) Act, 2008 on Service Provider

    assessment strategy

    66.67%

    33.33%

    33.33%

    11.11%

    0.00%

    Provisions of IT (Amendment) Act, 2008

    need to be appropriately incorporated in

    the client-Service Provider contracts

    IT (Amendment) Act, 2008 will have no

    impact as we need to comply with regulations

    we are subjected to

    IT (Amendment) Act, 2008 will strengthen

    the data protection initiatives of Indian

    Service Providers and therefore will help

    provide greater assurance to us for

    outsourcing our work to India

    Im not aware of IT (Amendment) Act, 2008

    Self declaration by Service Providers for

    complying/fulfilling clients security requirements,

    thereby making them liable for any security

    incident/data breach/violation should suffice

    IT (Amendment) Act,

    2008 needs to be

    incorporated in Client-

    Service Provider

    contracts this would

    assist in strengthening

    the data protection

    initiatives of Service

    Providers

    Clients perspective

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    Service Providers perspective

    Influence of IT (Amendment) Act, 2008 on Service Provider

    assessment strategy

    58.33%

    33.33%

    0.00%

    8.33%Others

    Not sure what will be the impact of IT

    (Amendment) Act, 2008

    IT (Amendment) Act, 2008 will strengthen the data

    protection initiatives of Indian Service Providers and

    therefore will help provide greater assurance to the

    clients outsourcing their work to India

    IT (Amendment) Act, 2008 will have no impact

    as clients need to comply with regulations

    they are subjected to

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    Service Provider Assessment Framework

    Third party assessmentsThird party assessments have gained importance in the Indian IT/BPO

    industry. Both Clients and Service Providers revealed that third parties

    should conduct Service Provider assessments based on a standardized

    assessment methodology.

    Majority of respondents emphasized that use of third parties would

    not only help in ensuring transparency and independence of the

    assessments but also save cost and efforts.

    A few Clients also reported that their organizations Executive

    Management may not approve/ recognize third party assessments.

    Options for third party assessments

    66.67%

    66.67%

    55.56%

    55.56%

    55.56%

    55.56%

    22.22%

    11.11%

    11.11%

    Third parties can conduct assessments of the

    Service Providers, based on a standardized

    assessment methodology, at a defined frequency

    Third Party assessments would save costs and

    efforts by avoiding the need for conducting

    assessments of multiple Service Providers

    Our regulators / customers may not approve or

    recognize Third Party assessments

    Third party assessments can be successful only

    if it is accepted by the outsourcing community

    and regulators

    Third Party assessments will bring transparency

    and independence

    Adopting Third Party assessments may raise

    trust and accountability issues

    My organizations Executive Management

    may not approve or recognize Third

    Party assessments

    The Third Party assessments will ensure that

    our resources are able to focus on improving security

    & privacy posture

    hird Party assessments may not be able to addressthe specific assessment requirements arising out

    of a particular Client-Service Provider relationship

    Majority of Clients

    and Service Providers

    report that third parties

    should conduct Service

    Provider assessments,

    based on a standardized

    assessment

    methodology at a

    dened frequency

    Clients perspective

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    Third party assessments

    would save cost and

    efforts by avoiding

    multiple assessments

    from different Clients

    Service Providers perspective

    Options for third party assessments

    66.67%

    41.67%

    41.67%

    41.67%

    33.33%

    16.67%

    16.67%

    Third party assessments may not be able to address

    the specific assessment requirements arising out

    a particular client Service Provider relationship

    Adopting Third Party assessments may raise

    trust and accountability issues

    Third parties can conduct assessments of the

    Service Providers, based on a standardized

    assessment methodology, at a defined frequency

    Third Party assessments would save costs and

    efforts by avoiding multiple assessments fromdifferent clients

    Third Party assessments will bring transparency

    and independence

    Third party assessments can be successful only if

    all our clients accept it, irrespective of industry,

    geography, Line of Service, etc.

    The Third Party assessments will ensure that our

    resources are able to focus on improving security &

    privacy posture instead of supporting multiple assessments

    Thirty three percent of Service Providers expressed their concernsregarding the use of third party assessments stating that they third party

    assessments could be helpful if their Clients accept these.

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    Third party assessorsThe survey highlighted that the auditing rms empanelled by a

    joint industry consortium of outsourcers and the Service Providers

    are the most potential third party assessors for conducting

    independent Service Provider assessments, seemingly

    acceptable to both the Client and Service Provider organizations.

    This option was selected by sixty six and fty percent of the Client

    and Service Provider organizations respectively. Such an industry

    consortium will represent the interests and challenges of both the

    sides the Clients and Service Providers.

    Potential entity acting as third party for conducting independent

    Service Provider assessments

    66.67%

    55.56%

    33.33%

    0.00%

    Auditing firms empanelled by a joint

    industry consortium of outsourcers and the

    Service Providers

    Auditing firms empanelled by the

    outsourcers industry consortium

    Self Regulatory Organizations (SRO)promoted by the Service Providers

    Auditing firms empanelled by

    the Service Providers

    Clients perspective

    Auditing rms

    empanelled by a jointindustry consortium

    of Client and Service

    Providers can serve as

    third party assessors

    for conducting Service

    Provider assessments

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    Service Providers perspective

    Potential entity acting as third party for conducting independent

    Service Provider assessments

    58.33

    50.00%

    25.00%

    8.33%

    Self Regulatory Organizations (SRO)

    promoted by the Service Providers

    Auditing firms empanelled by a joint

    industry consortium of outsourcers and the

    Service Providers

    Auditing firms empanelled by the

    outsourcers industry consortium

    Auditing firms empanelled by

    the Service Providers

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    Standards for Service Provider assessmentsNew domains of Information Security and Privacy have evolved. The

    domains which were not perceived to be critical are now among the

    most important security domains. Organizations have to comply with

    various models/standards/frameworks to adhere to the changing

    domains/rules and regulations. The organizations do no prefer to

    comply with so many standards and frameworks and this perception of

    the organizations was clearly evident from the survey results.

    The survey results highlighted that Client organizations are keen

    on adopting a new standard mapped to ISO 27001, NIST Special

    Publications, COBIT, ITIL etc. that meets all the regulatory requirementslike GLBA, HIPAA, PCI DSS etc., as a potential standard for third

    party assessments. While this view was common amongst Client

    organizations and Service Provider organizations with eighty nine and

    sixty seven percent respondents respectively selecting this option, in

    reality Clients may be more inclined towards new standard than the

    Service Providers because they demonstrate compliance to different

    regulations. Though this has an indirect impact on Service Providers but

    they are primarily driven by contractual obligations.

    Both Client and Service Provider organizations have similar number of

    respondents who selected ISO 27001 (sixty six percentages). It seemedthat organizations are satised with the acceptance of ISO 27001 as a

    A new standard mapped

    to ISO 27001, NIST-SP,COBIT, ITIL etc. that

    meets all the regulatory

    requirements like GLBA,

    HIPAA, PCI DSS etc. as

    a standard for third party

    assessments

    Potential assessment standards for third party assessments of

    Service Providers

    88.89%

    66.67%

    22.22%

    22.22%

    11.11%

    ISO 27001 standard

    A new standard mapped to ISO 27001, NIST

    SP, COBIT, ITIL, etc. that meets

    all the regulatory requirements like GLBA,

    HIPAA, PCI DSS, etc.

    Others

    Security and Privacy practices defined

    by SRO

    BITS shared assessment framework

    Clients perspective

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    Service Provider Assessment Framework

    Potential assessment standards for third party assessments of

    Service Providers

    66.67%

    66.67%

    16.67%

    8.33%

    ISO 27001 standard

    Security and Privacy practices defined by SRO

    BITS shared assessment framework

    A new standard mapped to ISO 27001,

    NIST-SP, COBIT, ITIL, etc. that meets all the regulatory

    requirements like GLBA, HIPAA, PCI DSS, etc.

    Service Providers perspective

    standard bearing in mind the challenge faced by Client organizations withrespect to the comfort/ assurance provided by Service Providers through

    ISO 27001 certication.

    Respondents in the Others category also suggested the use of a unied

    compliance framework for assessments.

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    Service Provider Assessment Framework

    Role of DSCI in Service Provider assessmentsThe question aimed to identify the role that DSCI could play as

    a Self Regulatory Organization (SRO), representative of both

    Client and Service Provider organizations, for conducting Service

    Provider assessments.

    Majority of the Client organizations (sixty seven percent) indicated

    that DSCI should create a panel of competent auditors to conduct

    Service Provider assessments on behalf of DSCI, develop code of

    practices for Data Security and Privacy that should be adopted by

    the industry and dene some criteria for assessing the maturity of

    the Service Providers.

    Fifty eight percent of the Service Provider organizations

    indicated that DSCI should develop a Service Provider

    assessment program that comprises of framework, processes

    and methodology for conducting Service Provider assessments.

    This option was also highlighted by a similar number of Client

    organizations (fty six percent).

    Clients perspective

    Role of DSCI in Service Provider assessments

    66.67%

    66.67%

    66.67%

    55.56%

    55.56%

    55.55%

    33.33%

    11.11%

    DSCI should establish a mechanism to manage

    the assessment results including sharing of results

    with clients and respective Service Providers

    Others

    DSCI should have code of practices for security

    and privacy that need to adopted by its members

    The code of practices should have some

    criteria for assessing the maturity of the

    Service Providers

    Code of practices should take a note of existing

    preparedness and initiatives of Service

    Providers in the areas of security and privacy

    DSCI should have mechanism to review

    the Service Provider assessments results

    on a regular basis

    DSCI should have a Service Provider assessment

    program that comprises of framework, processes,

    methodology for the assessment

    DSCI should create a panel of competent

    auditors who will conduct the assessments on

    behalf of DSCI

    Majority of Clients

    and Service Providersperpetuated that DSCI

    should have a Service

    Provider assessment

    program that consists of

    framework, processes

    and methodology of

    assessments

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    Service Provider Assessment Framework

    Role of DSCI in Service Provider assessments

    58.33%

    33.33%

    25.00%

    25.00%

    25.00%

    8.33%

    8.33%

    8.33%Others

    DSCI should have a Service Provider assessment

    program that comprises of framework, processes,

    methodology for the assessments

    DSCI should create a panel of competent

    auditors who will conduct the assessments

    on behalf of DSCI

    DSCI should have code of practices for security and

    privacy that need to adopted by its members

    The code of practices should have some criteria for

    assessing the maturity of the Service Providers

    DSCI should have mechanism to review the Service

    Provider assessments results on a regular basis

    DSCI should establish a mechanism to manage the

    assessment results including sharing of results with

    clients and respective Service Providers

    Code of practices should take a note of existing

    preparedness and initiatives of Service Providers

    in the areas of security and privacy

    Service Providers perspective

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    Service Provider Assessment Framework

    Outcome of Service Provider assessmentsThe survey results have unequivocally established that there

    should be organization-wide Security and Privacy maturity ratings,

    and domain specic ratings.

    It was also indicated that the both Client organizations as well as

    Service Provider organizations prefer ratings over certications.

    Outcome of Service Provider assessments Data Security

    77.78%

    55.56%

    44.44%

    DSCI should provide organization

    wide security maturity rating

    DSCI should provide domain specific

    maturity rating (e.g. Application

    security maturity rating)

    DSCI should provide organization

    wide security certification to

    Service Providers

    Outcome of Service Provider assessments Data Privacy

    88.89%

    44.44%

    DSCI should provide organization

    wide privacy certification to

    Service Providers

    DSCI should provide organization

    wide privacy maturity rating

    Clients perspective

    Organization-wide security

    and privacy maturity ratingsmay be provided as a

    result of Service Provider

    assessments

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    Service Provider Assessment Framework

    Service Providers perspective

    Outcome of Service Provider assessments Data Security

    58.33%

    33.33%

    16.67%

    DSCI should provide organization wide

    security maturity rating

    DSCI should provide organization wide

    security certification to Service Providers

    DSCI should provide domain specific maturity

    rating (e.g. Application security maturity rating)

    Outcome of Service Provider assessments Data Privacy

    75.00%

    50.00%

    DSCI should provide organization wide

    privacy maturity rating

    DSCI should provide organization wide

    privacy certification to Service Providers

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    Service Provider Assessment Framework

    Sharing of Service Provider assessment resultsMajority of Client organizations (sixty seven percent) conrm that

    if DSCI assumes the role of a third party assessor, DSCI should

    conduct the assessment of the targeted Service Provider and

    share the report with the Client. Client organizations are also in

    favor of DSCI conducting assessments of the Service Providers

    and sharing the report with Service Providers Clients based upon

    the authorization of Service Provider (thirty three percent), while

    only eleven percent of the Client organizations suggested DSCI

    conducting the assessment of the Service Provider and submitting

    its report to the Service Provider.

    In case DSCI assumes

    the role of a third-party assessor,

    Client and Service

    Provider organizations

    strongly support

    DSCI conducting

    the assessments of

    the targeted Service

    Provider and sharing the

    report with the Client onreceiving requests from

    the Client

    Most suitable assessment process in case DSCI assumes the role of a

    third party assessor

    66.67%

    33.33%

    11.11%

    11.11%

    On receiving request from the client, DSCI

    conducts the assessment of the targeted

    Service Provider and shares the report

    with the client

    On receiving request from the Service

    Provider, DSCI conducts the assessment of the

    Service Provider and based on theauthorization of Service Provider, DSCI shares

    the report with Service Providers clients

    On receiving request from the Service Provider,

    DSCI conducts the assessment of the Service

    Provider and submits its report to the Service Provider.

    Service Provider then shares this report with his

    clients when requested or otherwise

    Based on DSCI assessments, Service

    Providers are benchmarked against defined

    parameters and the report is made public

    Clients perspective

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    Service Provider Assessment Framework

    Most suitable assessment process in case DSCI assumes the role of a

    third party assessor

    41.67%

    41.67%

    33.33%

    8.33%

    8.33%Others

    Based on DSCI assessments, Service Providers are

    benchmarked against defined parameters and

    the report is made public

    On receiving request from the Service Provider, DSCI

    conducts the assessment of the Service Provider and

    based on the authorization of Service Provider,

    DSCI shares the report with SPs clients

    On receiving request from the client, DSCI conducts

    the assessment of the targeted Service Provider and

    shares the report with the client

    On receiving request from the Service Provider, DSCI

    conducts the assessment of the Service Provider and

    submits its report to the Service Provider. Service

    Provider then shares this report with his clients

    Service Providers perspective

    More than forty percent of the Service Provider respondents suggestedthat in case DSCI assumes the role of a third party assessor, DSCI should

    conduct the assessment of the targeted Service Provider on receiving

    request from the Client and share the report with the Client. Same number

    of Service Provider organizations also supports the process of DSCI

    conducting the assessment on receiving request from the Service Provider

    and submitting the report to Service Providers Clients upon authorization.

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    Service Provider Assessment Framework

    The survey revealed some interesting ndings and facts, bothfrom Client and Service Provider perspective which were further

    validated by the secondary research. Based on the study of

    different assessment frameworks and ndings of the survey,

    following are some of the salient preliminary recommendations for

    developing a Service Provider Assessment Framework:

    DSCI should play a vital role in conducting Service Providerassessments and sharing the outcome in the ecosystem. It

    should:

    Have an Service Provider assessment program that comprises of

    framework, processes, and methodology for assessmentsProvide an organization wide security and privacy maturity rating,

    and domain specic maturity rating that may be shared in the

    ecosystem after taking the due permission of the Service Providers

    A new standard mapped to prevalent standards should be

    considered as a potential assessment standard for third partyassessments of Service Providers

    DSCI as an industry initiative and a Self Regulatory Organization

    having representation from both the Client and Service Providerorganizations should empanel auditing rms for conductingindependent third party assessments.

    The advantages of prevalent assessment frameworks likeadaptability, exibility, comprehensibility of assessment areas,process-driven, and measurement-based assessment process

    should be the characteristics of the Service Provider assessmentframework that may be developed.

    Recommendations

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    The assessment model should not become an overhead for an

    organization. It should be able to provide specic improvementopportunities that an organization should be able to imbibe. The

    assessment criteria should be transparent to the extent possible.The framework should be reviewed at least on an annual basis

    by a competent set of technical and process experts, preferablycomprising DSCI members, members from third party assessors,

    and the industry.

    The assessment framework should be applicable regardless ofsize of the organization and nature/ complexity of its processes.

    For this purpose, the assessment methodology adopted should

    contain a preliminary set of questions that can be self-assessedby an organization.

    The Service Provider assessment framework should provideopportunities to organizations for implementing / performing thecontrol activities according to the needs of the organizations

    specic environment.

    The framework should follow a process-approach and outlinemeasurable assessment areas. The assessment areas that

    would link to specic business processes in an organization willbe easy to align with overall business goals and objectives.

    The framework should provide both assessment area/ domain

    based maturity rating and organization-wide security and privacymaturity rating that summarizes the appraisal results and permit

    comparison amongst organizations.

    The assessment model should be easy to comprehend andcompanies should be able to adopt on their own. All assessment

    areas should be broken down into a detailed list of specicand measureable steps that are easy to comprehend for

    assessment purposes.

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    Service Provider Assessment Framework

    Annexures

    The study team analysed the shortlisted assessment frameworksfor their advantages and disadvantages when applied to Client-

    driven Service Provider assessments. A summary of each

    framework is provided below:

    Malcolm Baldrige National Quality Program

    The Malcolm Baldrige National Quality Award program uses

    Malcolm Baldrige Assessment framework to assess the Quality of

    applying organization on seven critical areas for an organization.

    The framework is based on the processes implemented and

    the results achieved. The assessment methodology requires a

    self-assessment by the company applying for the award whichassists in dissolving the disparities between small, medium and

    large sized companies, and the way the control is implemented

    at the organization level. The framework has assigned separate

    weights to each individual area. However, the framework does not

    provide quantitative requirements for the criteria laid down. The

    requirements are subjective, and there are chances that

    the results when examined by different examiners may not

    be reproducible.

    Capability Maturity Model Integration (CMMI)The framework was developed by Software Engineering

    Institute (SEI) in an attempt to integrate several disciplines

    such as Process and Product development, Acquisition and

    Supplier Sourcing. The framework is focused towards software

    development organization however the framework can be

    implemented across various organizations. The framework can

    be implemented using Staged or Continuous representation.

    The Staged representation provides the Maturity level for

    organizations and the Continuous representation provides

    Capability Levels for as a measure assigned individuallyagainst each process area. The framework is exible and

    provides opportunities to organizations for undertaking the

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    activities according to their organization specic environment.For assessments the framework undertakes a Process based

    approach thereby adding value to the organization in the process

    of being assessed for maturity.

    BITS Shared Assessment Program

    The nancial services industry increasingly relies on information

    technology (IT) Service Providers to support the delivery of

    nancial services. The BITS shared assessment framework

    was developed by BITS IT Service Providers Working Group

    to address the concerns, arising out of increased regulatory

    scrutiny of nancial institution risk assessment and management

    of outsourced IT services. The framework adopts a risk based

    approach for conducting the assessments. The framework can

    be used as a reference by to create a common understanding of

    the nancial services industrys needs among Service Providers

    and help to address known control weaknesses in outsourced IT

    services, resulting in more consistent and appropriate levels of

    management by nancial services companies that outsource IT

    services.

    The eSourcing Capability Model for Client Organizations(eSCM-CL)

    The eSCM was developed by a consortium led by Carnegie

    Mellon Universitys Information Technology Service Qualication

    Center (ITSqc). The eSCM is best practices capability models

    with two purposes (1) to give Client organizations guidance that

    will help them improve their capability across the sourcing life-

    cycle, and (2) to provide Client organizations with an objective

    means of evaluating their sourcing capability. The model aims

    at assisting Client organizations to continuously evolve, andimprove their capabilities to develop stronger, enduring and more

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    Service Provider Assessment Framework

    trusting relationships with other Service Providers, and to meet

    the dynamic demands of business. The eSCM model provides

    the organizations the exibility to choose from framework based

    (using the framework as best practices) or evaluation based

    (using the framework to undertake a formal assessment). The

    eSCM for Client organizations is composed of 95 practices

    covered under three dimensions Sourcing Life-cycle, Capability

    Area, and Capability Level.

    Crisil Rating Methodology

    CRISIL rates companies in variety of sectors. Since each sector

    has its own nuances, CRISIL has customized rating criteria and

    methodology for each sector to make the ratings exercise apt and

    meaningful. Extensive research is undertaken by Crisil before

    assigning rating to an organization. The rating methodology

    adopts a risk-based approach thereby helping the organization

    to al