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A.5.19 / A.5.21 / A.15.1 / NIST SP 800-53 SA-9 / CIS-15.1 ISO/IEC 27001:2022 Annex A

Do you collect and review certifications (ISO 27001, SOC 2, PCI DSS) before onboarding Tier 1 vendors?

Demonstrate that the organization systematically collects, reviews, and validates security certifications from Tier 1 vendors before onboarding, ensuring third-party security posture meets defined risk thresholds prior to granting access or service commencement.

Description

What this control does

This control establishes a vendor risk management process requiring collection and review of relevant security certifications (ISO 27001, SOC 2, PCI DSS) prior to engaging Tier 1 vendors—those with access to critical systems, sensitive data, or who provide mission-critical services. The organization maintains a centralized repository of vendor certifications, verifies their validity, currency, and scope alignment with the vendor's service delivery, and documents approval decisions before contract execution. This proactive due diligence reduces third-party risk exposure by validating that high-impact vendors maintain independently audited security controls commensurate with the organization's risk appetite.

Control objective

What auditing this proves

Demonstrate that the organization systematically collects, reviews, and validates security certifications from Tier 1 vendors before onboarding, ensuring third-party security posture meets defined risk thresholds prior to granting access or service commencement.

Associated risks

Risks this control addresses

  • Onboarding vendors with insufficient security controls who subsequently suffer data breaches exposing the organization's sensitive data or customer information
  • Failure to detect fraudulent, expired, or out-of-scope certifications leading to false assurance about vendor security posture
  • Supply chain attacks exploiting weak security practices at third-party vendors who lack validated security programs
  • Regulatory non-compliance when vendors handling regulated data (payment card, healthcare, personal data) lack required certifications such as PCI DSS
  • Reputational damage and customer trust erosion following security incidents at uncertified vendors performing critical business functions
  • Contractual liability and financial loss when vendor security failures violate service level agreements or data protection obligations
  • Inadequate vendor security monitoring and accountability resulting from lack of baseline security standards established during onboarding

Testing procedure

How an auditor verifies this control

  1. Obtain the organization's vendor classification policy and confirm the definition of 'Tier 1' vendors including criteria such as data access level, system criticality, and business impact.
  2. Request the complete vendor inventory and filter for all Tier 1 vendors onboarded within the audit period.
  3. Select a representative sample of Tier 1 vendors (minimum 10 or 100% if fewer than 10) ensuring coverage across different service categories and data access types.
  4. For each sampled vendor, retrieve the vendor onboarding package including certification documentation, review notes, approval records, and onboarding date timestamps.
  5. Verify that certifications (ISO 27001, SOC 2 Type II, PCI DSS as applicable) were collected prior to the vendor's onboarding date and were valid (not expired) at time of onboarding.
  6. Examine documented evidence of certification review including verification of issuing body authenticity, scope alignment with services provided, and any noted exceptions or risk acceptances.
  7. Validate that formal approval was documented by authorized personnel (vendor risk committee, CISO, or designated authority) before contract execution or system access was granted.
  8. Test one instance where a vendor lacked appropriate certifications to confirm the process includes risk escalation, compensating controls documentation, or onboarding rejection procedures.
Evidence required Vendor onboarding packages containing certification copies (ISO 27001 certificates with accreditation marks, SOC 2 Type II reports with opinion letters, PCI DSS Attestations of Compliance), certification review checklists or assessment forms documenting scope verification and expiration date checks, approval emails or workflow system records showing sign-off by authorized personnel with timestamps, vendor tier classification register, and the vendor risk management policy defining certification requirements by vendor tier.
Pass criteria All sampled Tier 1 vendors have documented evidence of relevant security certifications collected, reviewed for validity and scope alignment, and formally approved prior to their onboarding date, with no exceptions lacking documented risk acceptance by senior management.