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Your Vulnerability Disclosure Policy Can Be Easier Than You Think

Findings | vulnerability disclosure
Supply Chain Security

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It’s easy to recognize the importance of creating a vulnerability disclosure policy. Vulnerability disclosure policies, or VDPs, are important because they help you track vulnerabilities within your supply chain and determine how to disclose security risks that arise within the supply chain. That’s a best practice for any business, not to mention a formal requirement for companies wishing to do business with the DOD and U.S. government agencies.

It can be pretty hard, however, to figure out how to define and enforce such a policy. If you’re like many businesses, you may struggle to determine which types of vulnerabilities to disclose, how to report them, and how to integrate these rules into a policy document that your business uses as a systematic guide whenever supply chain vulnerabilities arise.

Fortunately, it’s easy enough to work past these challenges. By taking a step-by-step approach to creating a vulnerability disclosure policy, you can define and enforce disclosure rules tailored to your business’s needs with much less effort than you may imagine.

The main purpose of vulnerability disclosure

Establishing an effective vulnerability disclosure policy starts with understanding what such a policy is supposed to do.

Vendor disclosure programs  have two main benefits:

Streamlined vulnerability reporting: A VDP defines who in your organization handles vulnerability reporting. This is important because many companies don’t know who the right person is to generate and distribute reports. Without a predefined reporting policy, you’re likely to end up with delays, or reports that never happen at all because no one knew who was supposed to create them.

Real-time reporting: Just as important, VDPs make it possible to react in real-time to vulnerabilities and breaches. As soon as you detect a security issue, you can report it to stakeholders or CISA, as required based on factors like which systems the incident impacts and how severe it is. The ability to disclose issues immediately and be fully transparent demonstrates a strong commitment to security on the part of your organization, which in turn helps your brand weather security events. Rapid disclosure may also be a compliance requirement for some businesses, as we’ve noted. But rapid disclosure means you need a complete view over your whole supply chain, not an easy task unless you have an automation tool to help with checking and reporting vulnerabilities.

Every VDP should be designed with these benefits in mind.

The six components of a vulnerability disclosure policy

To enable efficient, real-time vulnerability reporting, you should create a VDP in the form of a document that details six key facets of vulnerability disclosure.

1. Compliance policies

Your VDP should specify which compliance rules your business needs to meet, and which vulnerability disclosures those rules require.

The details in this section of the VDP will vary depending on your business and its compliance context. Not only do compliance requirements vary between geographies and industries, but businesses may also be exposed to different mandatory disclosure rules based on factors like the size of the business and the nature of a given breach. These are a few of the important policies you may come across ISO27001, NIST, ENISA, CMMC ISO, GDPR, HIPPA, CPPA (to name a few), and these need to be kept up-to-date with compliance rules changing every so often.

Whatever your specific requirements are, the goal of this section of your VDP should be to spell out the business’s disclosure responsibilities relative to its compliance mandates. 

2. Contractual obligations

In addition to compliance mandates, your business may be required by the contracts it signs with vendors, customers or partners to disclose vulnerabilities. Thus, one section of your VDP should address contractual vulnerability disclosure obligations.

Be sure to detail in this section not just when and to whom you have to disclose security issues, but also how the disclosures should be communicated. Typically, your agreements with other businesses will specify how communication is to be maintained in this context. By including this detail in your VDP, you ensure that you can find it easily, without having to piece through contracts.

3. Supply chain obligations

If vulnerabilities arise somewhere in your supply chain as opposed to your own systems, you may need to disclose those, too. Your VDP should include a section that spells out your obligations in this regard. It should also include information about how you maintain visibility into your supply chain and determine that a vulnerability has affected it.

4. Risk management and assessment

Every vulnerability is unique, and the ability to contextualize it based on its seriousness is critical for effective disclosure. Toward this end, define within your VDP how to calculate the overall security severity of each vulnerability, as well as how this security score impacts your disclosure procedures.

If you use risk assessment tools to automate the scoring process (as you should if you want it to take place in real-time and with minimal effort on the part of your team), include that information in the VDP, too.

5. Insurance coverage

In many cases, insurance can cover at least some losses incurred due to a security issue within your supply chain. For this reason, be sure that your VDP details which security insurance you have and how it applies to disclosures. 

6. Incident response plans

Disclosing vulnerabilities is one thing, mitigating is another.. Your VDP should include an overview of how your business responds to security incidents in order to ensure that they are remediated. In addition, if you’re required to keep stakeholders aware of progress toward remediation while an incident response is underway, spell out how you’ll do that within your VDP. 

How vulnerability disclosure statements optimize security

With a comprehensive VDP statement, you ensure that you are prepared to react in a way that minimizes the incident’s impact on your business, your vendors, your partners, your customers, and your supply chain in general.

In turn, you can make informed decisions about the following:

  • When to keep doing business with vendors who introduced a vulnerability into your supply chain
  • How to work with vendors to keep their risk levels low – and, by extension, keep your supply chain secure
  • When to switch to different vendors to lower your risk
  • Communicate effectively both “upstream” (meaning with your vendors and suppliers) and “downstream” (with customers and partners) when a vulnerability arises, as the image below from FIRST.org, a global organization focused on security improvements, illustrates

You can’t prevent every vulnerability or security incident. But you can prepare ahead of time to react quickly and effectively in meeting your obligations to disclose security issues when they happen – whether they stem from a vulnerability within your own IT estate or a problem that originated with another business in your supply chain.

You can make the vulnerability disclosure process even more efficient, which automates supply chain security detection and reporting.

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