GV.SC-05 says requirements to address cybersecurity risks in supply chains are established, prioritized and integrated into contracts and other types of agreements with suppliers and other relevant third parties. What you expect from a supplier should be written into the agreement, scaled to how critical they are.
What good looks like
A standard set of security terms that goes into default contract language. Terms get stricter for critical suppliers. The contract says how compliance can be verified, how information is shared with the supplier and its own suppliers, and how performance is monitored through the relationship.
How to implement it
- Set requirements by tier from GV.SC-04. A critical supplier handling customer data needs more than a low risk software tool.
- Build a clause library. Common items: breach notification time frames, security standards the supplier must follow, right to review evidence or audit, subprocessor disclosure and approval, data handling and deletion on exit, and incident cooperation.
- State how compliance is verified, such as annual evidence of a third party assessment or a completed security questionnaire.
- Define information sharing rules with the supplier and its sub tier suppliers, so you know who else touches your data.
- Put monitoring into service level agreements. Include security performance measures, such as vulnerability fix times or incident notice periods, and review them through the relationship.
- Route every contract through a security check before signature. Track exceptions.
Evidence to collect
- The clause library and the tier to requirements mapping.
- Signed contracts showing the clauses for critical suppliers.
- Records of exceptions with approvals.
- SLA reports or reviews showing security performance monitoring.
Common gaps
- The supplier's paper is signed with no security terms at all.
- The same light terms are used for every supplier, regardless of criticality.
- Requirements are stated but no way to verify them is defined.
- Renewals roll over automatically and nobody revisits the terms.
Be ready to be the supplier too
Your own customers will ask you for the same terms. Keeping your clause library tidy helps with both sides of the table, and it speeds up security reviews when a buyer sends over their requirements.
Sample clause topics by tier
Tier one: breach notice within a stated window, evidence of an independent assessment each year, subprocessor list and change notice, right to review evidence, data return or deletion on exit, and incident cooperation. Tier two: breach notice, subprocessor disclosure and data deletion on exit. Tier three: standard terms of service with a quick check for data handling. Counsel should draft the actual wording. Your job is to decide which topics matter for which suppliers and make sure they appear.
Quick check
Do we need custom contracts for every supplier?
No. Use a standard clause library and apply the stricter set to critical suppliers. Custom negotiation is only needed where a supplier will not accept the defaults.
What if a supplier refuses security terms?
Record it as an exception with an owner, assess the added risk, and either accept it formally at the right level or choose another supplier.
Sources
- NIST Cybersecurity Framework 2.0 Reference Tool, subcategory GV.SC-05: https://csrc.nist.gov/projects/cybersecurity-framework/filters
- NIST Cybersecurity Framework overview: https://www.nist.gov/cyberframework
The CSF is voluntary guidance. There is no CSF certification, so this post describes how to work toward the outcome, not how to pass an audit.
