The Ultimate Guide to Scalable Third-Party Risk Management (TPRM) for SaaS
ISO 27001, SOC 2, and GDPR Compliance Done Right
SaaS organizations thrive on speed, agility, and partnerships. However, with growth comes expanding third-party exposure—vendors, cloud providers, contractors, and AI tools all become intertwined with core operations. Each connection introduces risk. Left unchecked, these risks can derail compliance efforts, compromise sensitive data, and damage trust.
To stay audit-ready for ISO/IEC 27001:2022[1], SOC 2[2], and GDPR[3], SaaS companies need more than a checkbox approach. They need a TPRM program that is structured, scalable, and embedded into the business lifecycle.
This in-depth guide breaks down the process of building a resilient, audit-ready TPRM program that integrates security, compliance, and automation from day one.
⚖️ Step 1: Define the Strategy and Align with Compliance Goals
Start with a clear purpose: your TPRM program must support compliance while being operationally practical. Each framework sets expectations:
• ISO/IEC 27001:2022
Annex A.15 requires controls for managing supplier relationships, including security requirements in contracts and monitoring third-party performance[1].
• SOC 2 Trust Services Criteria
CC7.1 mandates organizations to monitor vendor services that could impact security, availability, or confidentiality[2].
• GDPR
Articles 28–32 require data controllers to only use processors (vendors) who implement appropriate security safeguards, especially around personal data[3].
Action Plan
Map Framework Requirements: Build a crosswalk that aligns ISO, SOC, and GDPR controls.
Develop a Unified Policy: Create a single TPRM policy with embedded control objectives covering all three frameworks.
Assign Ownership: Use a RACI model to designate responsibilities across Procurement, Security, Legal, and Privacy.
Create a Vendor Tiering Model: Use a risk-based matrix to classify vendors by:
Data sensitivity (e.g., access to PII, PHI)
System access (production, APIs, CI/CD pipelines)
Business criticality (impact on SLAs or revenue)
Regulatory exposure (GDPR, HIPAA, etc.)
📊 Step 2: Build a Vendor Inventory and Classification Engine
You can’t protect what you can’t see. Start by identifying all vendors who touch your data, systems, or operations.
Vendor Discovery Sources
Procurement systems (e.g., Coupa, Ariba)
Accounting platforms (e.g., NetSuite)
IAM/SSO tools (e.g., Okta, Azure AD)
SaaS management platforms (e.g., Torii, BetterCloud)
Shadow IT scans and Chrome extensions audits
Classification Framework
Tier 1: High Risk
Access to production systems or sensitive data
Use of privileged credentials or encryption keys
SaaS tools integrated into mission-critical workflows
Tier 2: Moderate Risk
Internal tools used for day-to-day operations
SaaS tools connected to development environments
No PII but could affect productivity
Tier 3: Low Risk
No system or data access
Examples: office supply vendors, HR training providers
Each tier determines the depth of review, documentation requirements, and reassessment frequency.
🔐 Step 3: Conduct Risk-Based Due Diligence
Due diligence isn’t just a formality—it’s the proof auditors will ask for. Tier 1 vendors should undergo the most rigorous review.
For ISO 27001 Alignment[1]:
Request Statement of Applicability (SoA)
Review controls for:
Access Control (A.9)
Cryptographic Protection (A.10)
Operations Security (A.12)
Supplier Management (A.15)
For SOC 2 Alignment[2]:
Request SOC 2 Type II reports
Validate control coverage and test results
Check for unresolved exceptions or high-risk findings
For GDPR Alignment[3]:
Validate Data Processing Agreements (DPAs)
Confirm international transfer safeguards (SCCs or BCRs)
Verify breach notification timelines and DPO contact
Use Standardized Questionnaires
SIG Lite/Core for broad vendor security reviews[4]
CAIQ for cloud-native services[5]
Validate Evidence
Request:
Penetration test reports
Security policy excerpts
Infrastructure diagrams or data flows
Leverage SecurityScorecard or BitSight to monitor vendor ratings over time[6]
Automate Workflow
OneTrust Vendorpedia for risk questionnaires, evidence storage, and reporting[7]
ServiceNow GRC for orchestration and lifecycle integration[8]
🛎️ Step 4: Embed TPRM Into the Vendor Lifecycle
Too often, vendors are onboarded before risk reviews occur. Fix this by operationalizing TPRM:
• Procurement
Require security intake forms as part of RFPs or purchase requests
Auto-trigger tier classification and notify Security/Privacy based on risk
• Legal
Embed GDPR-compliant DPAs[3]
Require security SLAs, breach notification clauses, audit rights
Standardize fallback clauses for vendors who resist obligations
• Security
Require MFA, VPN, RBAC validation before provisioning access
Block access to production until control verification is complete
Review penetration tests for production-facing vendors
• Automation
Use Whistic for easy vendor collaboration and assessment sharing[10]
Trigger workflows from tools like Coupa, Ironclad, Jira
Integrate alerting via Slack, MS Teams, and Jira for escalations
📊 Step 5: Monitor, Reassess, and Offboard Vendors
Risk doesn’t end after onboarding. Vendors evolve, and so must your oversight.
Continuous Monitoring
Require vendors to report incidents within 72 hours (GDPR Article 33)[3]
Track:
SOC 2 & ISO 27001 certification expirations
Pentest timelines and findings remediation
Reassessment Cadence
Tier 1: Annually or upon major change
Tier 2: Every 18–24 months
Automate reminders in LogicGate or ServiceNow GRC
Responsible Offboarding
Remove all credentials from IAM, VPN, and SaaS platforms
Validate data deletion or return with evidence (GDPR Article 28(3)(g))[3]
Archive all documentation (assessments, DPAs, contracts) for 3–7 years
⚖️ GRC Automation: Scale with Confidence
Manual TPRM is unsustainable at scale. Automate to reduce friction, improve audit readiness, and increase accuracy.
Core Features to Automate
Tier-based risk workflows
Evidence collection
Due diligence assignments
Escalation alerts
Executive dashboards
Recommended Platforms
LogicGate Risk Cloud for flexible workflow builds
OneTrust for privacy and compliance mapping[7]
Vanta for rapid assessments tied to SOC 2[7]
SecurityScorecard or BitSight for posture tracking[6]
Dashboard KPIs
% of Tier 1 vendors with current SOC 2
of overdue reassessments
Top 10 vendors by risk exposure
Vendors missing DPA or security documentation
🔗 Final Thoughts
A truly mature TPRM program isn’t just about compliance—it’s about proactive risk defense. By embedding TPRM into the vendor lifecycle, aligning with ISO 27001, SOC 2, and GDPR, and leveraging automation, SaaS companies can:
Strengthen audit posture
Improve vendor accountability
Reduce exposure from weak links
Build trust with customers and regulators
📛 References
[1] ISO/IEC 27001:2022. International Organization for Standardization. https://www.iso.org/standard/82875.html
[2] AICPA Trust Services Criteria. https://www.aicpa.org/resources/article/trust-services-criteria
[3] General Data Protection Regulation (EU) 2016/679. https://eur-lex.europa.eu/eli/reg/2016/679/oj
[4] Shared Assessments SIG Questionnaire. https://sharedassessments.org/sig/
[5] Cloud Security Alliance CAIQ. https://cloudsecurityalliance.org/research/caiq/
[6] SecurityScorecard. https://securityscorecard.com/
[7] OneTrust Vendorpedia. https://www.onetrust.com/products/vendorpedia/
[8] ServiceNow GRC. https://www.servicenow.com/products/governance-risk-and-compliance.html
[9] NIST SP 800-161 Rev. 1. https://csrc.nist.gov/publications/detail/sp/800-161/rev-1/final
[10] Whistic Vendor Security Platform. https://www.whistic.com/