Domain · Cyber third-party risk (TPRM)

Your critical third parties, managed from selection to exit.

We map your suppliers and providers, assess their criticality, carry out due diligence, strengthen the clauses, monitor their security over time and prepare exit plans.

Situations

You are in the right place if…

  • You have no up-to-date list of your IT providers, nor of what they do for you.
  • A critical supplier suffered a cyberattack, and you learnt from the press that your data was involved.
  • Your contracts provide for no incident notification deadline, no audit right and no reversibility.
  • You send the same questionnaire to all your suppliers, without ever using the answers.
  • Your authority or auditor asks for your register of providers and your exit strategies.
Our conviction

A critical third party is part of your perimeter: its risk is managed, from selection to exit.

A large share of incidents now comes through a provider: a managed service provider, a software vendor, a cloud service. Outsourcing an activity does not outsource its risk.

So we treat each third party according to its criticality: a light review for most, in-depth due diligence, solid clauses, continuous monitoring and an exit strategy for those you really depend on.

Our approach

From mapping to exit strategy.

Effort proportionate to each third party’s criticality, to focus the work where it reduces risk.

  1. 01MapProviders and suppliers, services rendered, data entrusted, functions supported, chained subcontractors.

    You getA register of third parties ranked by criticality

  2. 02AssessProportionate questionnaires, evidence requested, certifications checked, non-intrusive technical observations, remotely.

    You getAn assessment per critical third party

  3. 03ContractSecurity clauses, incident notification, audit right, data location, reversibility.

    You getTemplate clauses and amendments

  4. 04Monitor and prepare the exitPeriodic review, tracking of incidents and gaps, exit strategy for critical third parties.

    You getContinuous monitoring and exit plans

What the texts say

What the texts expect of third-party management.

DORA, NIS 2 and the GDPR converge: know your third parties, choose them on guarantees, contract and be able to exit.

  • DORADORA art. 28(1) · DORA art. 28(3) · DORA art. 28(5)

    Financial entities manage ICT third-party risk within their risk management framework, keep a register of information on all their ICT services contracts and only contract with providers that comply with appropriate information security standards.123

  • DORADORA art. 28(8)

    For services supporting critical or important functions, they put exit strategies in place.4

  • NIS 2 · ReCyFNIS 2 art. 21(2), point (d) · NIS 2 art. 21(3) · ReCyF v2.5, objectif 3

    The directive asks Member States to require of entities supply chain security, taking into account their suppliers’ cybersecurity practices; the ReCyF (working version) sets them the objective of an up-to-date list of their providers and of processes, notably contractual, to ensure their services comply.567

  • GDPR · CNIL guideRGPD art. 28(1) · Guide CNIL sécurité, fiche 14, F14-PE-01 · Guide CNIL sécurité, fiche 14, F14-MC-04

    The controller only uses processors providing sufficient guarantees; the CNIL likewise recommends using only such processors, and considering the whole subcontracting chain, not only direct processors.8910

Our engagement

The same topic, at three levels of engagement.

You choose the level; the scope and deliverables are set by contract.

Level 01

Monitor

We keep the third-party register up to date and monitor critical third parties at agreed intervals.

Deliverables
  • Register of third parties and their criticality
  • Watch on incidents and public findings for critical third parties
  • Alerts on assessments and contracts to renew
Level 03

Drive

We run the programme with your procurement, legal and business teams, without making the changes in your systems.

Deliverables
  • Management of assessments and reminders
  • Tracking of third parties’ gaps and action plans
  • Register ready for the authority or auditor
Accelerators

What we bring from day one.

Supplier questionnaires

Security questionnaires proportionate to the third party’s criticality, ready to send.

Template clauses

Security, incident notification, audit, location, reversibility: clauses to adapt with your lawyers.

Your tracking web app

Register of third parties, assessments, contracts and gaps in one tool shared with your teams.

Frequently asked questions

Before we start.

Must we assess all our suppliers?

No. All are listed, but effort follows criticality: a light review for most, in-depth due diligence and continuous monitoring for those your activities or sensitive data depend on.

What about an unavoidable supplier that refuses our clauses?

Document the risk, look for compensating measures on your side, and have the residual risk accepted by the right person. For a financial entity subject to DORA, the exit strategy then becomes all the more important.4

Is the DORA register of information the same as a third-party register?

It is a regulated form of it, centred on ICT services contracts. For a financial entity, we keep both together so each piece of information is entered only once.2

Do you audit our suppliers on site?

No. We assess your suppliers remotely: questionnaires, evidence requested, non-intrusive technical observations. Where criticality justifies an in-depth audit and the contract allows it, we help you find the right auditor, whom you mandate, and fold its findings into the follow-up.

Start with your ten most critical third parties.

Describe your main providers and what they do for you. We come back to you with a scoping proposal.

Sources

The excerpts quoted.

Exact text, in its original language, from the frameworks extracted from the official text.

Show the 10 excerpts quoted
  1. 1DORA art. 28(1)32022R2554-a28-p1
    Financial entities shall manage ICT third-party risk as an integral component of ICT risk within their ICT risk management framework as referred to in Article 6(1), and in accordance with the following principles:
    Normative force
    directly applicable EU law (regulation, level 1)
    Source
    Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector
    Version
    CELEX 32022R2554 — ELI reg/2022/2554
    Official text
  2. 2DORA art. 28(3)32022R2554-a28-p3
    As part of their ICT risk management framework, financial entities shall maintain and update at entity level, and at sub-consolidated and consolidated levels, a register of information in relation to all contractual arrangements on the use of ICT services provided by ICT third-party service providers. The contractual arrangements referred to in the first subparagraph shall be appropriately documented, distinguishing between those that cover ICT services supporting critical or important functions and those that do not. Financial entities shall report at least yearly to the competent authorities on the number of new arrangements on the use of ICT services, the categories of ICT third-party service providers, the type of contractual arrangements and the ICT services and functions which are being provided. Financial entities shall make available to the competent authority, upon its request, the full register of information or, as requested, specified sections thereof, along with any information deemed necessary to enable the effective supervision of the financial entity. Financial entities shall inform the competent authority in a timely manner about any planned contractual arrangement on the use of ICT services supporting critical or important functions as well as when a function has become critical or important.
    Normative force
    directly applicable EU law (regulation, level 1)
    Source
    Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector
    Version
    CELEX 32022R2554 — ELI reg/2022/2554
    Official text
  3. 3DORA art. 28(5)32022R2554-a28-p5
    Financial entities may only enter into contractual arrangements with ICT third-party service providers that comply with appropriate information security standards. When those contractual arrangements concern critical or important functions, financial entities shall, prior to concluding the arrangements, take due consideration of the use, by ICT third- party service providers, of the most up-to-date and highest quality information security standards.
    Normative force
    directly applicable EU law (regulation, level 1)
    Source
    Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector
    Version
    CELEX 32022R2554 — ELI reg/2022/2554
    Official text
  4. 4DORA art. 28(8)32022R2554-a28-p8
    For ICT services supporting critical or important functions, financial entities shall put in place exit strategies. The exit strategies shall take into account risks that may emerge at the level of ICT third-party service providers, in particular a possible failure on their part, a deterioration of the quality of the ICT services provided, any business disruption due to inappropriate or failed provision of ICT services or any material risk arising in relation to the appropriate and continuous deployment of the respective ICT service, or the termination of contractual arrangements with ICT third-party service providers under any of the circumstances listed in paragraph 7. Financial entities shall ensure that they are able to exit contractual arrangements without:
    Normative force
    directly applicable EU law (regulation, level 1)
    Source
    Regulation (EU) 2022/2554 of the European Parliament and of the Council of 14 December 2022 on digital operational resilience for the financial sector
    Version
    CELEX 32022R2554 — ELI reg/2022/2554
    Official text
  5. 5NIS 2 art. 21(2), point (d)32022L2555-a21-p2-4
    supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers;
    Normative force
    EU law to be transposed (directive): not directly applicable, requires national transposition
    Source
    Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive)
    Version
    CELEX 32022L2555 — ELI dir/2022/2555
    Official text
  6. 6NIS 2 art. 21(3)32022L2555-a21-p3
    Member States shall ensure that, when considering which measures referred to in paragraph 2, point (d), of this Article are appropriate, entities take into account the vulnerabilities specific to each direct supplier and service provider and the overall quality of products and cybersecurity practices of their suppliers and service providers, including their secure development procedures. Member States shall also ensure that, when considering which measures referred to in that point are appropriate, entities are required to take into account the results of the coordinated security risk assessments of critical supply chains carried out in accordance with Article 22(1).
    Normative force
    EU law to be transposed (directive): not directly applicable, requires national transposition
    Source
    Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (NIS 2 Directive)
    Version
    CELEX 32022L2555 — ELI dir/2022/2555
    Official text
  7. 7ReCyF v2.5, objectif 3recyf:obj-3
    Les entités [importantes ou essentielles] réalisent et maintiennent à jour une liste des prestataires et fournisseurs informatiques intervenant dans la réalisation de leurs activités ou dans la fourniture de leurs services et avec lesquels il existe une relation de droit ou de fait ainsi que le périmètre et la nature de la prestation ou du service fourni. Les entités [importantes ou essentielles] mettent en place des processus visant à s’assurer, notamment par la voie contractuelle de la conformité des prestations informatiques dont elles bénéficient aux obligations auxquelles l’entité est assujettie notamment en matière de gestion des risques qui menacent la sécurité de leurs réseaux et systèmes d’information et de notification des incidents importants.
    Normative force
    obligation (decree, resilience bill)
    Source
    ReCyF — Référentiel Cyber France (NIS 2, transposition nationale)
    Version
    2.5 du 17/03/2026 (version de travail)
    Status
    Working version: not binding until the transposition is enacted
    Official text
  8. 8RGPD art. 28(1)32016R0679-a28-p1
    Where processing is to be carried out on behalf of a controller, the controller shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of this Regulation and ensure the protection of the rights of the data subject.
    Normative force
    directly applicable EU law (regulation, level 1)
    Source
    Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
    Version
    CELEX 32016R0679 — ELI reg/2016/679
    Official text
  9. 9Guide CNIL sécurité, fiche 14, F14-PE-01F14-PE-01
    Faire appel uniquement à des sous-traitants présentant des garanties suffisantes (notamment en termes de connaissances spécialisées, de fiabilité et de ressources).
    Normative force
    recommendation (soft law)
    Source
    Guide pratique RGPD — Sécurité des données personnelles
    Version
    2024 (mise à jour 2026)
    Official text
  10. 10Guide CNIL sécurité, fiche 14, F14-MC-04F14-MC-04
    Toute la chaine de sous-traitance (sous-traitants des sous-traitants) devrait être considérée et non seulement les sous-traitants directs.
    Normative force
    recommendation (soft law)
    Source
    Guide pratique RGPD — Sécurité des données personnelles
    Version
    2024 (mise à jour 2026)
    Official text