Re: HECVAT Security Assessment Question

[Velislav K Pavlov <VelislavPavlov () FERRIS EDU>]

Rob, it's common for vendors to refuse to complete the risk assessment. Especially if they don't have their act 
together when it comes to assuring information security and privacy. We transitioned to using HECVAT as a template, but 
we also request attestation in the form of qualified third party assessment. This can be PCI DSS, HIPAA audit, NIST 
800-30 audit, ISO27001 certificate, proof of on-going vulnerability discovery and remediation, SSAE16 SOC 2 Type 2, CSA 
STAR, etc. It depends on the type of data and compliance requirements surrounding it. 

When we receive push back from the vendor or the institution, we resort to due care and due diligence. In our risk 
analysis, we assess qualitative and quantitatively the risk, exposure, impact, and likelihood based on discovered 
vulnerabilities and the identified type of data and attack surface. We make a recommendation that the risk is low, 
medium, high, or critical. We outline what the risk is and specify recommended corrective actions which are actionable. 
If the University leadership decides to accept the risk, we ask them to complete risk acceptance form. It raises 
awareness that my team has done our due care and diligence to do our job and help our leadership make educated 
decisions. It specifies why the risk is acceptable and requires sign off from the VP, Dean for the area, IT Security, 
and the CTO/CIO. Please let me know if you are interested in the risk assessment form or acceptance. I can share via 
email. 

Vel Pavlov | Coordinator, IT Security 
M.Sc. ISM, CISSP, C|HFI, C|EH, C)PTE, 
Security+, CNA, MPCS, ITILv3F, A+ 
VelPavlov () ferris edu


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-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Rob 
Milman
Sent: Thursday, July 13, 2017 11:30 AM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: Re: [SECURITY] HECVAT Security Assessment Question

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________________________________

Hi everyone,

I've been watching this thread with interest. We made the decision to begin using the HECVAT this spring to replace our 
SaaS assessment that was just not detailed enough. I current am working on 5 different engagements with cloud service 
providers and 3 of them have outright refused to complete the HECVAT. The other 2 are being evaluated and they haven't 
got back to me yet.

Some of the vendors that have rejected the HECVAT have provided their own documentation, but I can find no evidence of 
a third-party assessment. We have gone as far as telling the institution that we cannot support the cloud vendor as a 
risk assessment was not completed, the institution has gone ahead and signed contracts with these vendors anyway, 
without our acceptance.

Has anyone else had vendors refuse to complete the HECVAT? What has been the result? Is there a lighter version of the 
HECVAT that you would be willing to share?

Our institution is beginning to question the hard line we have taken with regards to cloud vendors, we may have to 
stand down.

Thanks,

Rob

-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of José A. 
Domínguez
Sent: Monday, July 10, 2017 4:45 PM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: Re: [SECURITY] HECVAT Security Assessment Question

Hello Sue. Your approach seems similar to what I am trying to do at UO.
I am engaging the office of Purchasing and Contracting Services and working on adopting HECVAT as part of their 
evaluation criteria for vendor selection. That way it's part of what the vendors need to do if they want our business 
and it's part of what departments need to look for when engaging businesses. The question is agreeing on what kind of 
cloud service solution requires what level of evaluation. I'll let you know how successful this approach is.

José.


On 7/7/17 5:14 AM, Sue McGlashan wrote:
> Hi Mark
>
> You derailed the conversation exactly into what I was talking about yesterday within our team - speediness vs 
> effectiveness. We need to be both effective and efficient, but effective does take time. Please see more below, and 
> thank you for opening the conversation.
>
>     >   At Brown, we are trying to move towards adopting HECVAT/HECVAT Lite for all vendor assessments as well. So 
> far, we haven’t run into the IBM scenario yet and we had our first instance of a vendor (Workfront) who had already 
> seen it and turned it around almost instantly, thanks for whomever forged the way for us!
>
>      >   If I could derail this conversation slightly, I’d be really interested in learning what your staffing to 
> support vendor assessments looks like. We seem to be continuously trying to play catch up with assessments
>
> Yes, we play a game of catch up all of the time, and any delayed 
> projects seem to arrive in the middle of a high volume of projects, 
> not when we had planned time to complete them  … we all know this 
> story
> - and I am sure you all also have internal projects, and you probably also need to look at both privacy and security.
>
>     > and it’s taking way more time than the cycles we have allotted. A vast majority of our time seems to be tied up 
> in chasing down information and getting people to actually respond!
>
> Agreed about the time, and to make it worse, sometimes the response is poor, so although a questionnaire is provided, 
> it is filled in by marketing, or else the vendor has a weak security team - i.e. we cannot use it as is.
>
> Solution? -  Please let me know if you have other suggestions.    I am adjusting our process - we need a better 
> intake, so that as vendor responses comes in, we quickly review the supplied documentation, and immediately contact 
> the vendor if the information is inadequate. This should reduce the overall time per project, but it will interrupt 
> current projects. I am hoping for a longer-term win.
>
>     > Although in some cases, wading through the reams of documentation from a vendor can take significant time as 
> well. At present, our team of two-part time people (very part time on paper for at least one of these anyways) seems 
> to be consistently trying to do contract reviews and security assessments on just North of 20 contracts concurrently. 
> I’m trying to figure out if we are just hugely inefficient, we are attempting to be too detailed in our reviews, or 
> we are truly understaffed. Are we the only ones in this situation? Anyone have a better model?
>      > Mark
>
> Overall, it takes time!  I am looking at how we can more efficiently complete an assessment, but I do not want to 
> change to a check box approach since we have discovered some concerns that such an approach would not have.  However, 
> when I asked the team to be more efficient, that was interpreted as rushing the work, resulting in the need to 
> re-review some of the assessment.
>
> No, you are not the only ones in this situation.
> If we decide an assessment must be completed, we should be thorough.
> Yes, I think if we are to do all of the assessments, we will need more staff. (but e.g. workfront - hopefully in the 
> longer term we will be able to share the results of our security reports/assessments, so we are also not each 
> individually reviewing each vendor).
>
> But could we triage better?  Probably.
>
> We are working towards a self-assessment for some smaller internal applications, followed by providing an application 
> vulnerability scan, and random full assessments. This idea evolved from listening to talks at the Educause conference.
>
> Thanks
> Sue McGlashan