CTPRP Leak Questions

Incident response and incident notification are two related but distinct processes that organizations should follow when dealing with security incidents. Incident response is the process of identifying, containing, analyzing, eradicating, and recovering from security incidents, while incident notification is the process of communicating the relevant information about the incident to the appropriate internal and external stakeholders, such as senior management, regulators, customers, and media12.

Not all security incidents are security breaches, which are defined as unauthorized access to or disclosure of sensitive or confidential information that could result in harm to the organization or individuals3. A security incident may become a security breach based on the analysis of the impact, scope, and severity of the incident, as well as the applicable legal and regulatory requirements. When a security breach is confirmed or suspected, the organization should trigger its incident notification or crisis communication process, which should include the following elements:

• A clear definition of roles and responsibilities for notification and communication
• A list of internal and external stakeholders who need to be notified and their contact information
• A set of predefined templates and messages for different types of incidents and audiences
• A communication strategy and timeline that aligns with the incident response plan and the business continuity plan
• A feedback mechanism to monitor and measure the effectiveness of the communication and adjust as needed

Incident notification and communication are critical for managing the reputation, trust, and compliance of the organization, as well as for mitigating the potential legal, financial, and operational consequences of a security breach. References:

• 1: Incident Response Plan: Frameworks and Steps
• 2: A Guide to Incident Response Plans, Playbooks, and Policy
• 3: What is Incident Response? Plan and Steps
• : Incident Response and Breach Notification
• : Incident Response Communication: Best Practices
• : The Importance of Incident Response Communication

Indemnification is a contractual obligation by which one party agrees to compensate another party for any losses or damages that may arise from a specified event or circumstance. Mutual indemnification means that both parties agree to indemnify each other for certain losses or damages, such as those caused by a breach of contract, negligence, or violation of law. Mutual indemnification can enable each party to share the amount of information security risk, as it can provide a mechanism for allocating the responsibility and liability for any security incidents or breaches that may affect either party or their customers. Mutual indemnification can also incentivize each party to maintain adequate security controls and practices, as well as to cooperate and communicate effectively in the event of a security incident or breach.

The other options are not contract clauses that enable each party to share the amount of information security risk, because:

• A. Limitation of liability is a contract clause that limits the amount or type of damages that one party can claim from another party in the event of a breach of contract or other legal action. Limitation of liability does not enable each party to share the amount of information security risk, as it can reduce or cap the liability of one party, but not necessarily distribute or balance the risk between both parties.
• B. Cyber insurance is a type of insurance policy that covers the costs and losses resulting from cyberattacks, data breaches, or other cyber incidents. Cyber insurance does not enable each party to share the amount of information security risk, as it can transfer or mitigate the risk to a third-party insurer, but not necessarily allocate or share the risk between both parties.
• C. Force majeure is a contract clause that excuses one or both parties from performing their contractual obligations in the event of an unforeseen or unavoidable event or circumstance that is beyond their control, such as a natural disaster, war, or pandemic. Force majeure does not enable each party to share the amount of information security risk, as it can suspend or terminate the contract in the event of a force majeure event, but not necessarily distribute or balance the risk between both parties.

References:

• Shared Assessments CTPRP Study Guide, page 62, section 5.2.2: Contractual Terms
• Third-Party Risk Management: Vendor Contract Terms and Conditions, section: Indemnification
• Cybersecurity risks from third party vendors: PwC, section: Contractual terms and conditions
• [Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Contractual Terms and Conditions

This statement is false because network connectivity or remote access may trigger a higher vendor risk classification for any third party that has access to the organization’s network, systems, or data, regardless of whether they process personal information or not. Network connectivity or remote access increases the exposure of the organization to cyberattacks, data breaches, or unauthorized access by malicious actors. Therefore, the organization should assess the security controls and practices of the third party, such as encryption, authentication, firewall, antivirus, and patch management, to ensure that they meet the organization’s standards and expectations. The organization should also monitor the network activity and performance of the third party, and establish clear policies and procedures for granting, revoking, or modifying access rights. The other statements (A, B, and C) are true regarding the primary factors in determining vendor risk classification, as they reflect the potential impact, likelihood, and severity of the risks associated with the vendor’s location, importance, and data processing. References:

• Vendor Classification, Shared Assessments
• Impact of Risk Attributes on Vendor Risk Assessment and Classification, SSRN
• Guide to Vendor Risk Assessment, Smartsheet
• How Do You Determine Vendor Criticality?, UpGuard

Data classification is the process of categorizing data according to its type, sensitivity, and value to the organization if altered, stolen, or destroyed1. Data classification helps an organization understand the risk level of its data and implement appropriate controls to protect it. Data can be classified into three risk levels: low, moderate, and high23. Low risk data are data that are intended for public disclosure or have no adverse impact on the organization’s mission, safety, finances, or reputation if compromised23. Sanitized customer data used for aggregated profiling are an example of low risk data, as they do not contain any personally identifiable or sensitive information that could be exploited for criminal or other wrongful purposes. Sanitized data are data that have been modified to remove or obscure any confidential or identifying information, such as names, addresses, phone numbers, etc. Aggregated data are data that have been combined or summarized from multiple sources to provide statistical or analytical insights, such as trends, patterns, averages, etc. Sanitized and aggregated data are often used for research, marketing, or business intelligence purposes, and do not pose a significant threat to the organization or the customers if exposed. References:

• 1: What is Data Classification? | Best Practices & Data Types | Imperva
• 2: Data Classification Guideline (1604 GD.01) - Yale University
• 3: Risk Classifications | University IT
• : Data Classification Policy - Shared Assessments
• : What is Data Sanitization? | Definition and Examples | Imperva
• : What is Data Aggregation? | Definition and Examples | Imperva