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SOC 2 CC9.2: Vendor and Business Partner Risk Management

Your vendors are an extension of your security posture—a weak link in their operations directly impacts your compliance status. CC9.2 requires you to systematically assess and manage risks from third parties that could affect your systems and data. This control separates compliant organizations from those exposed to vendor-related breaches.

What this means

CC9.2 mandates that your organization identify all vendors and business partners with access to systems or data, evaluate the risks they introduce, and implement controls to mitigate those risks. This includes assessing their security practices, contractual obligations, and ongoing monitoring. The goal is to ensure third parties maintain security standards aligned with your own compliance requirements.

How to comply

  1. 1.Maintain a complete inventory of all vendors and business partners, including those with system or data access
  2. 2.Develop and document a vendor risk assessment process that evaluates security, financial stability, and operational capability
  3. 3.Classify vendors by risk level based on the sensitivity of data or systems they can access
  4. 4.Define security requirements in contracts or service level agreements (SLAs) before engagement
  5. 5.Conduct initial security assessments (questionnaires, audits, certifications) before onboarding
  6. 6.Establish monitoring procedures for ongoing vendor compliance and incident reporting
  7. 7.Document remediation plans for identified vendor risks or security gaps
  8. 8.Review vendor performance and risk status at least annually or when material changes occur

Evidence auditors look for

  • Vendor inventory spreadsheet with contact details, access levels, and risk classification
  • Vendor risk assessment policy and procedures documentation
  • Completed vendor security questionnaires or audit reports
  • Third-party service agreements with security requirements and liability clauses
  • SOC 2 Type II or ISO 27001 certifications from critical vendors
  • Vendor performance review records and risk re-assessments
  • Incident reports involving vendors and remediation actions taken
  • Communication logs showing vendor notifi cation of security incidents
  • Contract termination or suspension records for non-compliant vendors

Frequently asked questions

When will FAQs be available?

The FAQ for this control is currently being prepared.

GRCWatch automates vendor risk assessment workflows, tracks compliance status across your entire partner ecosystem, and generates audit-ready evidence without manual spreadsheet maintenance.

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Related controls

CC6.1 — Logical Access ControlsCC6.2 — Prior to Issuing System CredentialsCC7.2 — System MonitoringCC8.1 — Incident Response