The vendor register template: every vendor, its risk and last review

Every vendor that touches your data, how critical it is, and when you last checked it.

A vendor register lists every vendor that touches your systems or data, how critical each one is, what data it holds, and when its security was last reviewed. It is the population every vendor control starts from.

The workbook is below with a short security questionnaire sheet. Start the list from your expense reports and single sign on apps so nothing is missed.

The template in full

Below is the whole workbook as it downloads. Every bracketed field, such as [Company name], is a detail to fill in before you adopt it. There is no form and no email address to hand over, and the file is yours to edit.

Vendor Register

Vendors

Each row is one vendor that stores, processes or can access [Company name] systems or data. Add a row before a new vendor is used, and update the review dates each time the vendor is reviewed.

VendorService providedData sharedCriticalitySOC 2 or ISO report on file?Report dateReviewed byLast reviewNext reviewContract endNotes

The sheet starts empty: one row per entry, under these columns.

Security questionnaire

Send this to a vendor that has no SOC 2 or ISO 27001 report. Record the answers, mark each one acceptable or not, and file the completed sheet with the vendor row.

SectionQuestionVendor answerAcceptable?Reviewer notes
Security programDo you have written information security policies approved by management and reviewed at least annually?
Security programWho is responsible for security at your company? Give a name and title.
CertificationsDo you hold a current SOC 2 Type 2 report or ISO 27001 certificate? If so, please share it.
CertificationsDo your employees complete security awareness training at hire and at least annually?
CertificationsDo you run background checks on employees who can access customer data, where local law allows?
EncryptionIs our data encrypted in transit with TLS 1.2 or higher?
EncryptionIs our data encrypted at rest? Describe the method and how keys are managed.
Access controlIs multi-factor authentication required for all employee access to production systems and our data?
Access controlIs access to our data limited to staff who need it, and reviewed at least quarterly?
Access controlIs access removed within one business day when an employee leaves?
Access controlDo you support single sign-on and MFA for our users of your service?
LoggingDo you log access to systems holding our data, and how long are logs retained?
LoggingAre logs monitored for suspicious activity, and by whom?
IncidentsDo you have a documented incident response plan that is tested at least annually?
IncidentsWill you notify us within 72 hours of confirming a security incident that affects our data?
SubprocessorsPlease list the subprocessors that store or process our data and their locations.
SubprocessorsWill you notify us before adding a new subprocessor?
Data location and deletionIn which countries and regions is our data stored and processed?
Data location and deletionWill you return or delete our data within 30 days of contract end, and confirm deletion in writing?
Business continuityDo you back up our data, how often, and when did you last test a restore?
Business continuityDo you have a business continuity and disaster recovery plan, and what are your recovery time and recovery point targets?
TestingDo you have an independent penetration test at least annually? Please share a summary of the latest results.
TestingHow quickly do you patch critical and high vulnerabilities?

How to use

  1. [Security owner role] owns this register. Add every vendor before it is given access to company or customer data.
  2. Set Criticality. High: stores or processes Restricted or Confidential data, or an outage would stop the product. Medium: holds Internal data or supports important work. Low: holds no sensitive data and is easy to replace.
  3. High vendors: collect a current SOC 2 Type 2 report or ISO 27001 certificate, read the exceptions and the complementary user entity controls, and confirm you perform those controls. If no report exists, collect the completed Security questionnaire.
  4. Medium vendors: collect a report if one is offered, otherwise a completed questionnaire or the vendor security page saved as a PDF.
  5. Low vendors: record the vendor, its service and the data shared. No further evidence is needed.
  6. Review every High and Medium vendor at least once a year. Record Last review, set Next review twelve months later, and store the report or questionnaire in a shared folder linked from Notes.
  7. When a vendor is no longer used, confirm access is removed and data is deleted, then record the end date in Notes. Keep the row for the audit period.

What an auditor checks

An auditor picks vendors from the register and asks for each review: the SOC 2 report you read, or the questionnaire answers, and your notes. Critical vendors need a review in the last year.

They also check the register is complete by comparing it with what the company pays for. A vendor in the expense report but not here is a finding. The vendor security questionnaire is the deeper review for critical vendors.

Which criteria it maps to

It supports CC9.2.1 A template is evidence of intent. The examination tests whether the control operated over the period, so keep the dated records the workbook produces. Every criterion, explained one by one, is on the Trust Services Criteria page.

Questions

What is a vendor register?
A list of every third party with access to your systems or data, with its criticality, the data it holds and the date of its last security review.
Which vendors belong in a SOC 2 vendor register?
Every vendor that stores, processes or can reach company or customer data, including cloud providers, software tools and contractors.
How often should vendors be reviewed?
Critical vendors once a year, others on a schedule your vendor policy sets. Record the date and what you read.

Sources

  1. TSP Section 100, Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy AICPA. The criteria themselves, including the common criteria every SOC 2 report covers.

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Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.