Vendor Security Questionnaire: What to Ask a Dev Shop
48% of breaches involve a third party. Your board has seen that slide. The number is real and it comes from the Verizon DBIR, but it doesn't mean what the room heard: the metric bundles three different situations together, and one of them is simply that you ran a vendor's vulnerable software.
The same gap opens when a vendor emails you its SOC 2 twelve minutes after you ask. Fast, professional, and silent on the only thing that matters: what the report covers. Nobody on the thread is going to raise it.
Closing that gap is what most vendor security questionnaires never do. Here's the move that beats a 300-row spreadsheet: for every credential a vendor offers, ask what it covers, who chose that coverage, and over what window.
A vendor security questionnaire is a structured set of questions a buyer sends a prospective supplier to establish what security controls that supplier operates, what its credentials actually cover, and what it will commit to in the contract.
Key takeaways
- The 2026 Verizon DBIR's 48% is the share of breaches with third-party involvement, and that metric "combines three different kinds of business relationship archetypes" [V1][V3]. Only one of them looks anything like handing a dev shop a repository [V5].
- A second, unrelated 48% sits in the same report: ransomware "grew again to 48% of all breaches, up from 44% from the previous year" [V9]. Say which one you mean.
- SOC 2 is an attestation report, not a certification. The vendor picks the scope, the categories and the type, and a type 1 "does not contain an opinion on the operating effectiveness of controls" [S1][S2][S5][S3].
- ISO/IEC 27001 certification is optional, and ISO wants the full reference: "certified to ISO/IEC 27001:2022" [K2][K3]. Check the scope and awarding body in the accreditation body's own database where one is published — UKAS's, for one — not in the PDF you were sent [K6][K7].
- No measured research shows that security questionnaires reduce breach incidence [F6]. Use them for what they do instead: discovery, risk allocation, contractual leverage.
What the 48% third-party number actually counts
The 2026 DBIR says that "breaches with third-party involvement have increased by 60% from last year's dataset, reaching 48% of total breaches" [V1], drawn from more than 31,000 incidents, over 22,000 of them confirmed breaches [V2]. Real finding, real dataset. It's also a construct, and the DBIR says so: the metric "combines three different kinds of business relationship archetypes," concerned with where initial access happened and where the breached data was stored [V3].
One archetype is a vendor in your software supply chain, where the data and the vector were both yours and the vector existed only because a vendor's product was vulnerable [V4]. Another is a vendor hosting your data. The third is a vendor with a connection into your environment, used for lateral movement [V5]. Only that last one resembles handing a dev shop a repository.
The 2025 edition was blunt about that seam: "Not every definition of third-party involvement in breaches would consider the usage of vulnerable software a third-party matter" [V6]. Exploitation of vulnerabilities is now the most common initial access vector, at 31% [V8]. Credential abuse sits below it, at 13% [V8]. A large slice of that 48% is "somebody's shipped software had a CVE and you were running it."
Two cautions. First, name which 48% you mean, because the same report carries two of them: ransomware "grew again to 48% of all breaches, up from 44% from the previous year" [V9]. Second, the trend line is young. The 2025 edition found "third-party involvement of some sort in 30% of all breaches we analyzed, up from roughly 15% last year" [V7]. Three editions, not a decade. And if you quote the window, use the DBIR's own phrasing: its 2026 executive summary says "this report's dataset covers Oct 2024 through Nov 2025" [V14].
The genuinely useful third-party findings are duller. Only 23% of third-party organisations fully remediated missing or improperly secured MFA on their cloud accounts [V10]. Not a questionnaire answer. That's how a vendor behaves after signature.
SOC 2 vs ISO 27001: what does each one actually attest?
Neither one attests that a vendor is secure. SOC 2 is an attestation report on controls the vendor itself chose to scope — not a certification [S1][S2]. ISO/IEC 27001 is a certification, and holding one is optional [K2]. Where a vendor is certified, what you want back is the version, the scope and the awarding body [K3][K6].
Start with the vocabulary; it's load-bearing. The Trust Services Criteria are established by the AICPA's Assurance Services Executive Committee "for use in attestation or consulting engagements" [S1], and the AICPA's own publication is titled SOC 2 Reporting on an Examination of Controls at a Service Organization [S12]. Attestation. Examination. Report. No certificate, no expiry sticker.
It's narrower than the phrase suggests in three ways, each of them the vendor's choice.
Scope. The criteria may be applied across an entire entity, at a subsidiary, division or operating unit level, within one function, or for one type of information [S2]. All of those produce a report that says SOC 2 on the front.
Coverage. The practitioner "may report on any of the trust services categories of security, availability, processing integrity, confidentiality, or privacy, either individually or in combination" [S5]. Security-only is a legitimate scope, and silent on confidentiality and privacy. Even Security is scoped to systems "protected against unauthorized access, unauthorized disclosure of information, and damage to systems" [S6] — not "we are secure."
Window. A type 2 covers design and operating effectiveness "throughout a specified period"; a type 1 "does not contain an opinion on the operating effectiveness of controls" [S3] and omits the tests of controls and their results entirely [S4]. A type 1 tells you the controls existed on a date.
The opinion is conditional on its face. In the AICPA's illustrative SOC 2 type 2 report, controls "operated effectively" to provide "reasonable assurance" the applicable criteria were met [S7]. The same report concedes in its Inherent Limitations paragraph that "controls at a service organization may not always operate effectively to meet the applicable trust services criteria" [S8], and restricts itself: "This report is not intended to be and should not be used by anyone other than these specified parties" [S10].
ISO/IEC 27001 does the same job with different nouns. Certification is optional: "companies implementing ISO/IEC 27001 can decide whether they want to go through a certification process" [K2]. ISO is also specific about how to quote it: standards "should always be referred to with their full reference, for example 'certified to ISO/IEC 27001:2022' (not just 'certified to ISO 27001')" [K3]. A certificate from an accredited body "may bring an additional layer of confidence" [K4]. Verify it yourself: UKAS's database publishes "Details of the organisation, scope and the awarding Certification Body" [K6], built partly to make it "easier to identify (and therefore prevent) fraudulent certificates" [K7].
None of which makes certifications worthless. An independently examined artefact beats a vendor's word. It's just scoped, and reading the scope is your job.
The one question that replaces the spreadsheet
One question, three clauses: what does it cover, who chose that coverage, and over what window?
It works on a SOC 2 because the AICPA hands you the answer sheet: the scope levels [S2], the five categories [S5], the two types [S3]. Three answers tell you whether the report covers the part of the business that will hold your code. It works on ISO because the version, the scope statement and the awarding body are all published [K3][K6]. Verify in the accreditation body's database where one is published, not in the PDF you were sent [K7].
The NCSC's supplier assurance list asks whether the supplier holds certifications "such as Cyber Essentials, Cyber Essentials Plus or ISO27001" [Q2], then asks the only follow-up that matters: "If so, does the scope of the certifications cover the parts of the service you will be using and how you will be using it?" [Q3]. No survey quantifies how often scope turns out narrower than buyers assumed [F8]. So ask per vendor.
Where your data goes, and who else touches it
Settle one question before you send a DPA: does this vendor process personal data on your behalf? Where it doesn't, GDPR Article 28 isn't engaged, and your instruments are the NDA, the IP assignment and access control [F12]. Test that premise rather than assuming it, because a repository carries commit author names and email addresses, and fixtures and config files are not always synthetic.
Where it is engaged, Article 28 — in the text as retained in UK law — says a controller "shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures" [G1], and mandates a written contract with eight terms, from documented instructions and Article 32 security through to deletion or return and audits [G2][G3].
The EDPB's guidance is where the useful buyer moves live: a processing agreement "should not merely restate the provisions of the GDPR" but give concrete detail on how the requirements will be met [G4]. So a DPA that reads like a photocopy of the regulation is a finding, not a deliverable. The Article 28(1) obligation "is a continuous obligation," verified at intervals including through audits [G7]. And audit-fee clauses that are "clearly disproportionate or excessive" make that audit right "purely theoretical" [G11]. If a vendor's DPA prices your audit out of existence, that clause is your questionnaire answer.
The EDPB does list "recognised international certifications, like ISO 27000 series" among documents that help here [G5]. Then it calls the assessment "a form of risk assessment" made case by case, and declines to publish an exhaustive list [G6]. Certification helps; it doesn't discharge the assessment.
Then geography. Transfers to an adequate country flow "without any further safeguard being necessary" [G15]. As at 20 August 2026 the list runs Andorra, Argentina, Brazil, Canada (commercial organisations), the Faroe Islands, Guernsey, Israel, the Isle of Man, Japan, Jersey [G16], New Zealand, the Republic of Korea, Switzerland, the United Kingdom, the United States (commercial organisations in the EU-US Data Privacy Framework), Uruguay and the European Patent Organisation [G17]. Check it on the day: Brazil is a recent addition and the UK's two 2021 decisions were renewed in December 2025 [G18]. Without adequacy, the 2021 SCCs remain the current clauses, with an additional set for importers directly subject to the GDPR still in development [G12][G14]. A DPA citing the pre-2021 clauses is stale paperwork [G13].
The question almost nobody asks a dev vendor: will live customer data ever sit somewhere your production controls don't reach? PCI DSS is the clearest precedent, and deliberately narrow. v4.0 rescoped the test-data requirement from "testing or development" to "pre-production" at 6.5.5 [P1] and clarified that "live PANs are not used in pre-production environments except where all applicable PCI DSS requirements are in place" [P2]. That rule is about live card numbers, not all personal data, so borrow its shape and not its authority. The ICO's AI guidance makes the same move for training data: de-identify it before it is extracted from its source [I2]. NIST's SSDF supplies the environment half: controls "to separate the environments from each other and from production environments" [N2], plus minimal human access to build systems [N4].
Three software vendor due diligence questions that aren't about security
Who owns the code. In the US, when a work is made for hire, "the party that hired the individual is considered both the author and the copyright owner" [C1]. A commissioned work qualifies only if it fits one of the statute's listed categories, there's a written agreement, the parties expressly agree it's a work made for hire, and all parties sign [C3]. Circular 30 is absolute about the consequence of missing one: "if a work fails to satisfy any of these requirements, it is not a work made for hire" [C4]. And the statute lists exactly nine eligible categories, none of which is computer software [C2].
All of that is US law. Elsewhere, the durable move is the question rather than the doctrine: does the contract contain a present assignment of all IP in the deliverables, signed by every individual who writes code? That last clause carries the weight, because the employee-versus-contractor line turns on agency factors [C5] — and a subcontractor three layers down may not be covered by what your vendor signed.
Who else touches it. Sub-processor authorisation is a term you can enforce [G9]. The NCSC gives you the operational version: which offshore locations, what controls apply there, and whether you'll be told if locations or offshore subcontractors change [Q9]. One more from the same list: is the supplier required to build a right to audit into its own subcontracts, where those affect your service [Q11]?
What happens on the way out. Article 28 already requires deletion or return of personal data [G3]. The NCSC's is broader: what the contract provides for secure deletion or return of your data and assets at exit, including transfer to another supplier [Q10]. Ask while you still have leverage.
The best vendor security questionnaire is already written, and free
Two documents cover most of what a mid-market buyer needs, and neither costs anything. The UK NCSC publishes a list of supplier assurance questions grouped into governance, incidents, network, data, offshoring, personal data, personnel, physical, testing and contract sections [Q1]. Will the supplier "connect, or have access to, your data, IT network or premises," and "how will this be limited, controlled, and monitored?" [Q5]. Do their users have "the minimum level of access to data and networks required to do their job and no more" [Q4]? Do you log their remote access sessions "to reflect the work done" [Q6], and do they penetration-test independently and remediate what turns up [Q8]? Then the one most buyers skip: how will you monitor changes in their risk profile over time [Q12], which is the continuous-obligation point again [G7].
The second is CISA's Secure Software Development Attestation Form, released in March 2024 for producers of software used by the US federal government [N10]. Four items, signed by a CEO or a designee who must be an employee with authority to bind the corporation [N11]: software developed and built in secure environments, with environment separation, logging of trust relationships, and MFA plus conditional access [N12]; a good-faith effort to maintain trusted source code supply chains using automated tools [N13]; provenance maintained "to the greatest extent feasible" [N14]; and automated vulnerability checking before releases and on an ongoing basis, plus a disclosure program with timely handling [N15]. A producer may instead submit an assessment by a FedRAMP-certified 3PAO [N16], and must notify the agency if it stops using those practices [N17].
That page carries an archive banner, so check its current federal standing before you treat it as a live mandate. As a borrowable minimum bar it holds up anyway, because it is short, it has a named signatory who can bind the company, and it matches SSDF's call for a disclosure policy [N8] researchers can actually find [N9]. Most bespoke questionnaires manage none of those three.
Now the uncomfortable part. No measured research shows that security questionnaires reduce breach incidence [F6]. That absence is itself a finding. The nearest peer-reviewed work is about internal cybersecurity audit, not SOC 2 and not buyer questionnaires: Slapničar and colleagues built a cybersecurity audit index and found it correlated with cyber-risk-management maturity but "is not related to the probability of a successful cyber attack" [O1]. Set that beside the AICPA's own Inherent Limitations paragraph [S8], though, and the picture holds: these artefacts document a control environment. They don't operate it. The questionnaire-fatigue figures everyone quotes trace back to vendor marketing pages with no named survey, sample or date [F7].
Use questionnaires for what they demonstrably do: discovery, risk allocation, contractual leverage. Not prevention.
The 15-question checklist to send any development vendor
Fifteen questions, each with the reason it earns a slot. This is the whole vendor security questionnaire. Lift it, and pair it with the code audit checklist when you need to judge the code itself.
- What does your SOC 2 cover — which entity, which systems, which categories? Scope runs from entity-wide down to a single data type; coverage can be any subset of the five categories [S2][S5][Q3].
- Is it a type 1 or a type 2, and what were the exact dates? A type 1 carries no operating-effectiveness opinion and no test results [S3][S4].
- Who's named in the restricted-use paragraph, and can we read the report under NDA? The detail is in the tests, not the cover page [S10].
- Which version of ISO/IEC 27001, which body, and is it accredited? Accreditation adds a layer of confidence, and UKAS, for one, publishes the scope [K3][K4][K6].
- Will you process personal data on our behalf? If no, the instruments are an NDA and an IP assignment; if yes, eight contract terms become mandatory [F12][G3].
- Does anyone need production access, on whose account, and is it the minimum? Least privilege caps the blast radius [Q4][Q5].
- Do we log your remote access sessions, with logs reflecting the work done? Unlogged vendor access is the DBIR archetype that resembles your situation [Q6][V5].
- Will live customer data ever appear in a non-production environment? PCI DSS says no for live card numbers without full controls; the ICO's AI guidance says de-identify training data before extraction [P2][I2].
- How are development and production separated, and who reaches the build systems? Segmentation and minimal toolchain access are the named practices [N2][N4].
- Which sub-processors, in which countries, and will you get our written authorisation before that changes? Prior authorisation is enforceable; the change notice is not automatic [G9][Q9].
- If data leaves the EEA, under which mechanism — adequacy or the 2021 SCCs? The adequacy list moves, and pre-2021 clauses are stale [G15][G12][G13].
- Have you had a material security breach or compromise you need to declare? This is the NCSC's wording, and asking it in writing puts the answer on the record before you sign [Q7].
- Do you penetration-test independently, remediate findings, and run a disclosure programme? Remediation is where third parties stall: at third-party organisations, resolving 50% of weak-password and permission-misconfiguration findings took almost eight months [Q8][N8][N9][V11].
- Does the contract assign all IP in the deliverables, signed by everyone who writes code? In the US, work made for hire fails entirely if one condition is missed [C1][C4].
- At exit, what happens to our data, our code, and your access? Deletion or return is a required DPA term, and it is negotiable only before signing [G3][Q10].
Read that back and notice what it's mostly about: scope, access and contract, not badges. That's deliberate, because most of those questions have a structural answer as well as a procedural one.
That's how You-Source is set up. Engineers work inside your environment, under your access controls. Code and data don't leave your environment without your explicit approval. NDA before access. 100% you own the code. Which means questions 6 through 9 and 14 — the whole access block, plus who owns the code — get answered by how the engagement is built rather than by a certificate [T17]. None of that excuses you from reading a scope paragraph. It means fewer of your answers depend on one.
The certificate was never the point. The scope paragraph is.
Frequently asked questions
What is the difference between SOC 2 and ISO/IEC 27001?
SOC 2 is an attestation report — an examination of controls the vendor itself chose to scope, against criteria the AICPA's Assurance Services Executive Committee established "for use in attestation or consulting engagements" [S1][S2][S12]. ISO/IEC 27001 is a certification, and obtaining one is optional [K2]. Where a vendor is certified, ISO asks for the full reference — "certified to ISO/IEC 27001:2022" — and UKAS, for one, publishes the scope and awarding body so you can verify them yourself [K3][K6]. There is no such thing as a SOC 2 certificate.
What is the difference between a SOC 2 type 1 and a type 2?
A type 2 covers design and operating effectiveness "throughout a specified period" [S3]. A type 1 "does not contain an opinion on the operating effectiveness of controls" [S3] and omits the tests of controls and their results entirely [S4]. A type 1 tells you the controls existed on a date; ask for the exact dates either way.
Do I need a DPA with a development vendor?
Only where the vendor processes personal data on your behalf. Where it doesn't, GDPR Article 28 isn't engaged, and your instruments are the NDA, the IP assignment and access control [F12] — though "code only" is a premise worth testing, since repositories carry commit author names and email addresses. Where it is engaged, Article 28 — in the text as retained in UK law — mandates a written contract with eight terms, from documented instructions and Article 32 security through to deletion or return and audits [G2][G3].
Is there a free vendor security questionnaire I can use?
Two, and neither costs anything. The UK NCSC publishes a list of supplier assurance questions grouped into governance, incidents, network, data, offshoring, personal data, personnel, physical, testing and contract sections [Q1]. CISA's Secure Software Development Attestation Form sets four items signed by a CEO or a designee who must be an employee with authority to bind the corporation [N10][N11] — that page carries an archive banner, so treat it as a borrowable minimum bar rather than a live federal mandate.
Do security questionnaires actually prevent breaches?
No measured research shows that security questionnaires reduce breach incidence [F6]. The nearest peer-reviewed work is about internal cybersecurity audit: Slapničar and colleagues built a cybersecurity audit index and found it correlated with cyber-risk-management maturity but "is not related to the probability of a successful cyber attack" [O1]. These artefacts document a control environment; they don't operate it.
Sources
- [C1] US Copyright Office Circular 30: when a work is made for hire, "the party that hired the individual is considered both the author and the copyright owner of the work." (Revised 08/2024) — https://www.copyright.gov/circs/circ30.pdf
- [C2] Circular 30 lists exactly nine categories of specially ordered or commissioned works eligible to be works made for hire; computer software is not among them. (Revised 08/2024) — https://www.copyright.gov/circs/circ30.pdf
- [C3] Circular 30: a commissioned work is a work made for hire only if it fits a listed category, there is a written agreement, the parties expressly agree it is a work made for hire, and all parties sign. (Revised 08/2024) — https://www.copyright.gov/circs/circ30.pdf
- [C4] Circular 30: "If a work fails to satisfy any of these requirements, it is not a work made for hire." (Revised 08/2024) — https://www.copyright.gov/circs/circ30.pdf
- [C5] Circular 30 sets out the common-law agency factors distinguishing employee from contractor: skill required, who supplied tools and space, tax treatment, benefits, and right to assign other work. (Revised 08/2024) — https://www.copyright.gov/circs/circ30.pdf
- [F6] Editorial verification, 2026-08-20: no study was found showing that completing a vendor security questionnaire reduces breach incidence. The nearest peer-reviewed measurement found cybersecurity audit effectiveness "is not related to the probability of a successful cyber attack" (Slapnicar et al. 2022, on internal audit) — https://ideas.repec.org/a/eee/ijoais/v44y2022ics1467089521000506.html
- [F7] Editorial verification, 2026-08-20: every circulating questionnaire-fatigue figure (hours per questionnaire, questionnaires per year, "300+ questions on average") traced to compliance-vendor marketing with no named study, sample or method. No primary was located — no source URL (absence of evidence, verified editorially)
- [F8] Editorial verification, 2026-08-20: no measurement exists quantifying how often a SOC 2 or ISO 27001 scope is narrower than a buyer assumes. The point is structural, not statistical — no source URL (absence of evidence, verified editorially)
- [F12] Editorial note on scope: a development vendor is a GDPR processor only where it processes personal data on your behalf. Where it touches code alone, Article 28 is not engaged and NDA, IP assignment and access control are the operative instruments — https://www.legislation.gov.uk/eur/2016/679/article/28
- [G1] GDPR Art. 28(1): a controller "shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures." (UK-retained text of Reg. 2016/679) — https://www.legislation.gov.uk/eur/2016/679/article/28
- [G2] GDPR Art. 28(3) requires a written contract setting out subject matter, duration, nature and purpose of processing, types of personal data and categories of data subject. (UK-retained text of Reg. 2016/679) — https://www.legislation.gov.uk/eur/2016/679/article/28
- [G3] GDPR Art. 28(3)(a)–(h) mandate: documented instructions; confidentiality commitments; Art. 32 security; sub-processor conditions; rights assistance; breach assistance; deletion/return; audits. (UK-retained text of Reg. 2016/679) — https://www.legislation.gov.uk/eur/2016/679/article/28
- [G4] EDPB Guidelines 07/2020 (v2.1): "the processing agreement should not merely restate the provisions of the GDPR" but give concrete detail on how requirements will be met. (Adopted 2021-07-07; v2.1 2022-09-20) — https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf
- [G5] EDPB para 95: demonstrating "sufficient guarantees" often requires documents such as external data protection audit reports and "recognised international certifications, like ISO 27000 series." (Adopted 2021-07-07) — https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf
- [G6] EDPB para 96: the sufficiency assessment "is a form of risk assessment" made case by case; the EDPB refuses to publish an exhaustive checklist of required documents. (Adopted 2021-07-07) — https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf
- [G7] EDPB para 99: the Art. 28(1) obligation "is a continuous obligation"; the controller should at appropriate intervals verify the processor's guarantees, including through audits and inspections. (Adopted 2021-07-07) — https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf
- [G9] EDPB para 128: the agreement must specify the processor may not engage another processor "without the controller's prior written authorisation" and whether it is specific or general. (Adopted 2021-07-07) — https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf
- [G11] EDPB para 145: audit-fee clauses that are "clearly disproportionate or excessive" would make Art. 28(3)(h) rights "purely theoretical" and are therefore improper. (Adopted 2021-07-07) — https://www.edpb.europa.eu/system/files/documents/2023-10/EDPB_guidelines_202007_controllerprocessor_final_en.pdf
- [G12] European Commission: "On 4 June 2021, the Commission issued modernised standard contractual clauses under the GDPR" — the 2021 SCCs remain the current set. (EC SCC page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
- [G13] The 2021 SCCs "replace the three sets of SCCs that were adopted under the previous Data Protection Directive 95/46" — pre-2021 SCC references in a vendor DPA are stale. (EC SCC page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
- [G14] The Commission is still "in the process of developing additional sets of SCCs" for transfers to importers whose processing is directly subject to the GDPR — that gap is not yet filled. (EC SCC page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
- [G15] EC adequacy effect: "personal data can flow from the EU (and Norway, Liechtenstein and Iceland) to that third country without any further safeguard being necessary." (EC adequacy page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
- [G16] EC adequacy list as retrieved on 2026-08-20: Andorra, Argentina, Brazil, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey. (EC adequacy page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
- [G17] EC adequacy list continued: New Zealand, Republic of Korea, Switzerland, United Kingdom, United States (commercial orgs in the EU-US Data Privacy Framework), Uruguay, European Patent Organisation. (EC adequacy page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
- [G18] Brazil now appears on the Commission's adequacy list, and the UK's two 2021 adequacy decisions were renewed in December 2025 — the list moved within the last 12 months. (EC adequacy page, retrieved 2026-08-20) — https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
- [I2] ICO: you may need to "apply de-identification techniques to training data before it is extracted from its source and shared internally or externally." (ICO AI and data protection guidance) — https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/guidance-on-ai-and-data-protection/how-should-we-assess-security-and-data-minimisation-in-ai/
- [K2] ISO: "companies implementing ISO/IEC 27001 can decide whether they want to go through a certification process" — certification is optional, not inherent to the standard. (ISO/IEC 27001:2022 page) — https://www.iso.org/standard/27001
- [K3] ISO instructs that standards "should always be referred to with their full reference, for example 'certified to ISO/IEC 27001:2022' (not just 'certified to ISO 27001')." (ISO/IEC 27001:2022 page) — https://www.iso.org/standard/27001
- [K4] ISO: holding a certificate from an accredited conformity assessment body "may bring an additional layer of confidence" because an accreditation body confirmed the certifier's competence. (ISO/IEC 27001:2022 page) — https://www.iso.org/standard/27001
- [K6] UKAS's accredited-certification database shows "Details of the organisation, scope and the awarding Certification Body" so a buyer can verify a certificate directly. (2021-07-11) — https://www.ukas.com/resources/latest-news/accredited-certification-database/
- [K7] UKAS says the database makes it "easier to identify (and therefore prevent) fraudulent certificates" — i.e. fake certificates are a known, named problem. (2021-07-11) — https://www.ukas.com/resources/latest-news/accredited-certification-database/
- [N2] SSDF PO.5.1 example: use network segmentation and access controls "to separate the environments from each other and from production environments." (2022-02) — https://nvlpubs.nist.gov/nistpubs/specialpublications/nist.sp.800-218.pdf
- [N4] SSDF PO.5.1 example 4: "Minimize direct human access to toolchain systems, such as build services. Continuously monitor and audit all access attempts and all use of privileged access." (2022-02) — https://nvlpubs.nist.gov/nistpubs/specialpublications/nist.sp.800-218.pdf
- [N8] SSDF RV.1.3: "Have a policy that addresses vulnerability disclosure and remediation, and implement the roles, responsibilities, and processes needed to support that policy." (2022-02) — https://nvlpubs.nist.gov/nistpubs/specialpublications/nist.sp.800-218.pdf
- [N9] SSDF RV.1.3 example 1 is to "Establish a vulnerability disclosure program, and make it easy for security researchers to learn about your program and report possible vulnerabilities." (2022-02) — https://nvlpubs.nist.gov/nistpubs/specialpublications/nist.sp.800-218.pdf
- [N10] CISA released the Secure Software Development Attestation Form on March 11, 2024, requiring producers of software used by the US federal government to attest to secure development practices. (2024-03-11 (page now flagged Archived Content)) — https://www.cisa.gov/secure-software-attestation-form
- [N11] The CISA form must be signed by the CEO or a designee "who must be an employee of the software producer and have the authority to bind the corporation." (OMB Control #1670-0052, expires 2027-03-31) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [N12] CISA attestation item 1: "The software is developed and built in secure environments," with separation of environments, logging of trust relationships, and MFA plus conditional access. (OMB Control #1670-0052) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [N13] CISA attestation item 2: the producer "makes a good-faith effort to maintain trusted source code supply chains" using automated tools for internal code and third-party components. (OMB Control #1670-0052) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [N14] CISA attestation item 3: the producer "maintains provenance for internal code and third-party components incorporated into the software to the greatest extent feasible." (OMB Control #1670-0052) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [N15] CISA attestation item 4 requires automated vulnerability checking on an ongoing basis and before releases, plus operating a vulnerability disclosure program with timely handling. (OMB Control #1670-0052) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [N16] A producer may instead submit a third-party assessment by a 3PAO that is "FedRAMP certified or approved in writing by an appropriate agency official" — self-attestation is the floor, not the ceiling. (OMB Control #1670-0052) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [N17] The CISA form also obliges the producer to notify any agency "if and when the producer ceases to make consistent use of the practices identified above." (OMB Control #1670-0052) — https://www.cisa.gov/sites/default/files/2024-04/Self_Attestation_Common_Form_FINAL_508c.pdf
- [O1] Peer-reviewed study of internal cybersecurity audit found the audit index correlated with risk-management maturity but "it is not related to the probability of a successful cyber attack." (Int. J. Accounting Information Systems, vol. 44, 2022) — https://ideas.repec.org/a/eee/ijoais/v44y2022ics1467089521000506.html
- [P1] PCI SSC: in PCI DSS v4.0 the test-data requirement moved from 6.4.3 to 6.5.5 and the term changed from "testing or development" to "pre-production" environments. (2022-05 (revision 1)) — https://listings.pcisecuritystandards.org/documents/PCI-DSS-v3-2-1-to-v4-0-Summary-of-Changes-r1.pdf
- [P2] PCI SSC: v4.0 "Clarified that live PANs are not used in pre-production environments except where all applicable PCI DSS requirements are in place." (2022-05 (revision 1)) — https://listings.pcisecuritystandards.org/documents/PCI-DSS-v3-2-1-to-v4-0-Summary-of-Changes-r1.pdf
- [Q1] UK NCSC publishes a free list of Supplier assurance questions grouped into governance, incidents, network, data, offshoring, personal data, personnel, physical, testing and contract sections. (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q2] NCSC asks buyers: "Does the supplier hold (or would you require them to hold) any cyber security certifications, such as Cyber Essentials, Cyber Essentials Plus or ISO27001?" (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q3] NCSC immediately follows up: "If so, does the scope of the certifications cover the parts of the service you will be using and how you will be using it?" (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q4] NCSC asks: "Do their users have the minimum level of access to data and networks required to do their job and no more?" — least privilege as a supplier question. (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q5] NCSC asks whether the supplier will "connect, or have access to, your data, IT network or premises" and "how will this be limited, controlled, and monitored?" (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q6] NCSC asks whether you "log their remote access sessions on your systems, with logs captured to reflect the work done." (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q7] NCSC asks: "Has the supplier suffered any material security breaches or compromises which they need to declare?" (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q8] NCSC asks whether the supplier "conduct[s] any independent security tests, such as penetration tests of their internal and external IT infrastructure and remediate any findings." (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q9] NCSC asks about offshoring: which locations, what controls, whether you will be notified if locations or offshore subcontractors change, and whether personal data is involved. (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q10] NCSC asks about contract exit: "what provisions are in the contract for secure deletion or return of your data/assets at contract exit," including transfer to another supplier. (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q11] NCSC asks whether you should require the supplier to "build in a 'right to audit' into contracts with their suppliers/subcontractors, where this affects the service to you." (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [Q12] NCSC asks: "How will you monitor for changes in the information risk profile of the supplier over time?" — assurance is a running process, not a signing event. (Published 2020-12-17) — https://www.ncsc.gov.uk/guidance/supplier-assurance-questions
- [S1] The Trust Services Criteria are established by the AICPA's Assurance Services Executive Committee "for use in attestation or consulting engagements" — the word is attestation, not certification. (2017 TSC, 2022 points of focus) — https://assets.ctfassets.net/rb9cdnjh59cm/2sK6Ih6dzy6t7aU6RQvoeD/d97a2a14609e74a1af1ce9ab0b142b69/92317096_trust_services_criteria_red-lined_version.pdf
- [S2] The TSC may be applied "across an entire entity", or at "a subsidiary, division, or operating unit level", or within one function, or for one type of information — scope is chosen, not fixed. (2017 TSC, 2022 points of focus) — https://assets.ctfassets.net/rb9cdnjh59cm/2sK6Ih6dzy6t7aU6RQvoeD/d97a2a14609e74a1af1ce9ab0b142b69/92317096_trust_services_criteria_red-lined_version.pdf
- [S3] AICPA: a type 2 SOC 2 covers design and operating effectiveness "throughout a specified period"; a type 1 "does not contain an opinion on the operating effectiveness of controls." (2017 TSC, 2022 points of focus) — https://assets.ctfassets.net/rb9cdnjh59cm/2sK6Ih6dzy6t7aU6RQvoeD/d97a2a14609e74a1af1ce9ab0b142b69/92317096_trust_services_criteria_red-lined_version.pdf
- [S4] A type 1 SOC 2 also omits "a detailed description of tests of controls performed by the service auditor and the results of those tests." (2017 TSC, 2022 points of focus) — https://assets.ctfassets.net/rb9cdnjh59cm/2sK6Ih6dzy6t7aU6RQvoeD/d97a2a14609e74a1af1ce9ab0b142b69/92317096_trust_services_criteria_red-lined_version.pdf
- [S5] AICPA: the practitioner "may report on any of the trust services categories of security, availability, processing integrity, confidentiality, or privacy, either individually or in combination." (2017 TSC, 2022 points of focus) — https://assets.ctfassets.net/rb9cdnjh59cm/2sK6Ih6dzy6t7aU6RQvoeD/d97a2a14609e74a1af1ce9ab0b142b69/92317096_trust_services_criteria_red-lined_version.pdf
- [S6] AICPA's Security category is defined as information and systems being "protected against unauthorized access, unauthorized disclosure of information, and damage to systems." (2017 TSC, 2022 points of focus) — https://assets.ctfassets.net/rb9cdnjh59cm/2sK6Ih6dzy6t7aU6RQvoeD/d97a2a14609e74a1af1ce9ab0b142b69/92317096_trust_services_criteria_red-lined_version.pdf
- [S7] In AICPA's illustrative SOC 2 type 2 report the opinion is that controls "operated effectively" to provide "reasonable assurance" the criteria were met — not that the system is secure. (AICPA illustrative report) (freely mirrored copy of the AICPA illustrative report, not an aicpa-cima.com URL) — https://www.ptoexchange.com/hubfs/PTO_December2019/pdf/SOC2_CSA_CCM_Report.pdf?hsLang=en
- [S8] AICPA illustrative report, Inherent Limitations: "controls at a service organization may not always operate effectively to meet the applicable trust services criteria." (freely mirrored copy of the AICPA illustrative report, not an aicpa-cima.com URL) — https://www.ptoexchange.com/hubfs/PTO_December2019/pdf/SOC2_CSA_CCM_Report.pdf?hsLang=en
- [S10] AICPA illustrative report, Restricted Use: "This report is not intended to be and should not be used by anyone other than these specified parties." (freely mirrored copy of the AICPA illustrative report, not an aicpa-cima.com URL) — https://www.ptoexchange.com/hubfs/PTO_December2019/pdf/SOC2_CSA_CCM_Report.pdf?hsLang=en
- [S12] The AICPA's own publication is titled "SOC 2 Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy" — the governing verbs are reporting and examination. (AICPA resource landing page) — https://www.aicpa-cima.com/resources/landing/system-and-organization-controls-soc-suite-of-services
- [T17] You-Source, Dev On Demand — the four operating claims quoted are verbatim from the page: engineers operate inside your environment under your access controls; "Code and data don't leave your environment without your explicit approval"; "NDA before access"; all code written for your project belongs to you — https://www.you-source.com/dev-on-demand
- [V1] Verizon 2026 DBIR: "breaches with third-party involvement have increased by 60% from last year's dataset, reaching 48% of total breaches." (2026 (19th edition)) — https://www.verizon.com/business/resources/Td15/reports/2026-dbir-data-breach-investigations-report.pdf
- [V2] 2026 DBIR analysed "more than 31,000" real-world security incidents, of which "more than 22,000 were confirmed data breaches" across organizations in 145 countries. — https://www.verizon.com/business/resources/executivebriefs/2026-dbir-executive-summary.pdf
- [V3] The 2026 DBIR says its third-party metric "combines three different kinds of business relationship archetypes" concerned with where initial access happened and where breached data was stored. — https://www.verizon.com/business/resources/Td15/reports/2026-dbir-data-breach-investigations-report.pdf
- [V4] DBIR archetype 1 is a vendor in the software supply chain: data and initial vector were under your control, but the vector existed only because of a vulnerability in a vendor product. (2026) — https://www.verizon.com/business/resources/Td15/reports/2026-dbir-data-breach-investigations-report.pdf
- [V5] DBIR archetype 2 is a vendor hosting your data; archetype 3 is a vendor with a connection into your environment, used for lateral movement (the Target pattern). (2026) — https://www.verizon.com/business/resources/Td15/reports/2026-dbir-data-breach-investigations-report.pdf
- [V6] The 2025 DBIR states plainly: "Not every definition of third-party involvement in breaches would consider the usage of vulnerable software a third-party matter." — https://www.verizon.com/business/resources/T16f/reports/2025-dbir-data-breach-investigations-report.pdf
- [V7] 2025 DBIR: "we found third-party involvement of some sort in 30% of all breaches we analyzed, up from roughly 15% last year" — the metric is only three editions old. — https://www.verizon.com/business/resources/T16f/reports/2025-dbir-data-breach-investigations-report.pdf
- [V8] 2026 DBIR: exploitation of vulnerabilities is now the most common initial access vector for breaches at 31%, while credential abuse fell to 13%. — https://www.verizon.com/business/resources/executivebriefs/2026-dbir-executive-summary.pdf
- [V9] 2026 DBIR: "Ransomware grew again to 48% of all breaches, up from 44% from the previous year" — a separate 48% from the third-party 48%. — https://www.verizon.com/business/resources/executivebriefs/2026-dbir-executive-summary.pdf
- [V10] 2026 DBIR: "only 23% of third-party organizations fully remediated missing or improperly secured multifactor authentication (MFA) on their cloud accounts." — https://www.verizon.com/business/resources/executivebriefs/2026-dbir-executive-summary.pdf
- [V11] 2026 DBIR: for weak passwords and permission misconfigurations at third parties, the time to resolve 50% of all findings reached "almost eight months." — https://www.verizon.com/business/resources/executivebriefs/2026-dbir-executive-summary.pdf
- [V14] 2026 DBIR self-describes its window as "this report's dataset covers Oct 2024 through Nov 2025" (see Notes — the phrasing is internally odd). — https://www.verizon.com/business/resources/executivebriefs/2026-dbir-executive-summary.pdf