As a cloud customer, it's crucial to keep tabs on all the third-party products and services involved in your cloud setup. This means putting together a detailed inventory of every vendor relationship, including key contacts, contracts, and risk info. Staying on top of this supply chain inventory is a must for effectively managing risks.
Where did this come from?
This control comes from the CSA Cloud Controls Matrix v4.0.10 released on 2023-09-26. You can download the full CCM spreadsheet from https://cloudsecurityalliance.org/artifacts/cloud-controls-matrix-v4.
The CCM provides a comprehensive set of security controls tailored for cloud environments. It was put together by a broad coalition of industry experts to establish a common baseline for cloud security.
For more background, check out:
Who should care?
This control is most relevant for:
- Supply chain managers responsible for third-party relationships
- Vendor management teams tracking contracts and contacts
- Risk managers assessing supply chain threats
- Compliance officers ensuring third-party oversight
- Security teams defending against supply chain attacks
What is the risk?
Without a comprehensive supply chain inventory, your organization faces several risks:
- Unidentified dependencies on high-risk vendors
- Inability to assess third-party security practices
- Challenges coordinating incident response with suppliers
- Exposure to supply chain threats like compromised updates
- Fines for violating third-party oversight regulations
While an inventory alone won't eliminate these risks, it's a foundational step for managing supplier relationships and detecting supply chain issues early. The more complete and up-to-date the inventory, the better equipped you'll be.
What's the care factor?
For most organizations, supply chain management should be a top security priority. Even a minor gap in third-party oversight could open the door to a major breach.
We've seen countless examples of attackers exploiting supplier access and vulnerabilities. Often, victims had little visibility into these relationships. An accurate inventory helps you proactively identify and mitigate such risks.
However, building a supply chain inventory does require ongoing effort. Be pragmatic and prioritize based on supplier criticality, data access, and risk profile.
When is it relevant?
A supply chain inventory makes sense for nearly every cloud deployment. It's especially critical for:
- Complex environments with many third-party components
- Strictly regulated industries like finance and healthcare
- Organizations with valuable data or intellectual property
- Global companies with international supply chains
You may be able to forgo a formal inventory for a small, low-risk deployment with limited external dependencies. But establish a clear threshold for when an inventory becomes necessary.
What are the trade-offs?
Implementing this control does come with costs and challenges:
- Upfront effort to assemble a comprehensive inventory
- Ongoing work to maintain accuracy as suppliers change
- Potential pushback from teams who see it as red tape
- Risk of inventory gaps despite good faith efforts
- Possibility of over-restricting suppliers based on the inventory
However, these drawbacks pale in comparison to the risks of operating blindly. Invest the time to get your inventory right - it's well worth it.
How to make it happen?
To build your supply chain inventory:
- Assign clear ownership of the inventory to a team or individual
- Define the scope (e.g. all suppliers, critical only, new vendors only)
- Create a template to capture key fields like:
- Supplier name, description, and category
- Products/services provided
- Contract terms, contacts, and account reps
- Data access, security certs, and risk assessment
- Integrate with other systems like procurement and vendor management
- Populate the inventory, starting with critical and high-risk suppliers
- Validate entries with the business and interview suppliers as needed
- Establish a regular cadence to review and update the inventory
- Use the inventory to inform third-party risk management processes
Aim for comprehensive coverage but don't let perfect be the enemy of good. Start lean and expand iteratively.
What are some gotchas?
A few things to watch out for:
- Legacy suppliers not in your official procurement system
- Resistance from teams who see information gathering as a burden
- Suppliers reluctant to share info due to confidentiality concerns
- Defining third parties too narrowly and missing key players
- Overreliance on supplier attestations vs independent assessments
Also ensure you have appropriate access permissions to create and maintain the inventory. Common IAM policies to allow:
organizations:ListAccounts/organizations:ListTagsForResourceiam:GetRole/iam:ListRolesec2:DescribeInstances/ec2:DescribeVpcsconfig:GetDiscoveredResourceCounts/config:ListDiscoveredResources
Refer to the AWS IAM documentation for more details on configuring permissions.
What are the alternatives?
While a centralized inventory is ideal, you could start with point-in-time snapshots or high-level supplier tiering if resources are constrained. Lean on procurement/vendor management teams who may track some of this info already.
Ultimately, there's no substitute for a comprehensive inventory. But don't let the perfect be the enemy of the good. Some visibility is better than none.
Explore further
For more on supply chain risk management, check out:
- NIST SP 800-161: Supply Chain Risk Management Practices
- CSA Cloud Vendor Assessment Questionnaire
- CIS Critical Security Control 15: Service Provider Management
Consider complementary CCM controls like DCS-06: Datacenter Security and IAM-02: Credential Lifecycle.
