TPRM RACI Matrix Examples

Most TPRM programs fail because nobody knows who owns what. You've seen it: procurement buys a critical SaaS tool, security finds out during a pentest, legal scrambles to review terms retroactively, and Risk gets blamed when something breaks.

A TPRM RACI matrix prevents this chaos by mapping every vendor lifecycle activity to specific owners. But generic templates miss the nuances. Your critical infrastructure vendor needs different oversight than your marketing analytics tool. Your 10-person security team operates differently than a 100-person enterprise SOC.

These real-world examples show how organizations actually structure vendor risk accountability—including what broke, what got fixed, and which edge cases nobody talks about until they happen.

Financial Services RACI: 500+ Critical Vendors

A regional bank managing 500+ vendors discovered their RACI matrix broke during their first major vendor breach. Their original structure assigned Risk as "Accountable" for all vendor decisions, creating a bottleneck that delayed critical security patches by 3-4 weeks.

Initial Structure (Failed)

Activity	Risk	Procurement	IT Security	Compliance	Business Owner
Vendor Selection	A/R	C	I	C	R
Risk Assessment	A/R	I	C	C	I
Contract Review	A	R	I	C	C
Ongoing Monitoring	A/R	I	C	C	I

The breach exposed three failures:

1. IT Security had no authority to force emergency patches
2. Business owners bypassed the process for "urgent" needs
3. Risk team couldn't scale reviews for 500+ vendors

Revised Structure (Current)

Activity	Risk	Procurement	IT Security	Compliance	Business Owner
Tier 1 Vendor Selection	C	R	A/R	C	A
Tier 2-3 Vendor Selection	I	A/R	C	I	R
Critical Patch Deployment	I	I	A/R	I	C
Quarterly Risk Review	A/R	C	R	R	C

Changes that fixed the bottleneck:

• Security owns emergency response for Tier 1 vendors
• Business owners accountable for Tier 2-3 selections
• Risk focuses only on quarterly reviews, not daily operations

Healthcare System RACI: PHI Access Controls

A 12-hospital system processing 2M patient records annually built their RACI around HIPAA's minimum necessary standard. Their unique challenge: clinical vendors need different oversight than administrative vendors, even at the same risk tier.

Clinical Vendor RACI

Activity	CISO	Privacy Officer	Clinical IT	Procurement	Department Chief
PHI Access Approval	C	A/R	R	I	A
BAA Execution	I	A/R	C	R	C
Access Review (Monthly)	R	A	R	I	C
Incident Response	A/R	R	R	I	C

Administrative Vendor RACI

Activity	CISO	Privacy Officer	Clinical IT	Procurement	Department Chief
System Access Approval	A/R	C	I	C	R
BAA Execution	C	R	I	A/R	I
Access Review (Quarterly)	A/R	C	I	I	R
Incident Response	A/R	C	R	I	I

Key difference: Privacy Officer owns clinical vendor decisions due to patient care implications, while CISO owns administrative vendor decisions focused on data security.

SaaS Company RACI: Continuous Monitoring at Scale

A 2,000-employee SaaS provider automated their RACI matrix after manual processes failed at 200+ vendors. Their continuous monitoring program assigns ownership based on risk signals, not static roles.

Dynamic RACI Triggers

Risk Signal	Primary Owner	Escalation Path	SLA
New CVE (CVSS 9+)	Security Ops	→ CISO → CTO	4 hours
Expired Certificate	IT Ops	→ Vendor Manager	24 hours
Financial Alert	Procurement	→ CFO	48 hours
Compliance Finding	GRC	→ Legal → CISO	72 hours

Automation Results

• 73% reduction in response time for critical vulnerabilities
• 91% of Tier 3 vendor issues resolved without escalation
• 2.5 FTEs saved through automated routing

Lessons learned:

1. Static RACI breaks beyond 100 vendors
2. Automated escalation paths prevent decision paralysis
3. Clear SLAs matter more than perfect role definitions

Common RACI Failure Patterns

The "Everyone is Responsible" Matrix

One Fortune 500 company assigned "R" to 3-4 roles per activity. Result: nobody took ownership during a ransomware event affecting 12 vendors. Fix: maximum 2 "R" assignments per activity, with clear primary/secondary designation.

The "CISO Owns Everything" Matrix

A startup made their CISO accountable for all vendor decisions. The CISO became a bottleneck, delaying vendor onboarding by 6-8 weeks. Fix: delegate operational decisions to team leads, keep CISO accountable only for policy and Tier 1 vendors.

The "Compliance is Optional" Matrix

A retail chain marked Compliance as only "Informed" for vendor selection. They discovered this error during PCI DSS audits when 15 vendors lacked required attestations. Fix: Compliance must be "Consulted" for any vendor touching regulated data.

Framework Alignment

Your RACI must map to your compliance requirements:

SOC 2 CC9.1: Requires clear vendor risk ownership

• Risk Management: Accountable for risk ratings
• IT Security: Responsible for technical controls
• Compliance: Consulted on control effectiveness

ISO 27001 A.15: Supplier relationship security

• Procurement: Responsible for contract security clauses
• Legal: Accountable for liability terms
• Security: Consulted on technical requirements

NIST CSF ID.SC-2: Supplier risk assessments

• Risk: Accountable for assessment methodology
• Business Owner: Responsible for vendor justification
• Security: Responsible for technical validation

Edge Cases Your RACI Must Address

Vendor Acquisition: When your vendor gets acquired, who decides if the relationship continues? Most RACIs miss this. Assign: Legal (A), Risk (R), Procurement (R), Business Owner (C).

Shadow IT Discovery: When security finds an unauthorized vendor, standard RACI doesn't apply. Create an exception path: Security (A/R), Business Owner (R), Risk (C), Compliance (I).

Multi-Vendor Incidents: When multiple vendors contribute to one incident, single-vendor RACI breaks. Solution: designate an Incident Commander role that overrides normal RACI during active incidents.

Vendor Bankruptcy: Financial distress requires rapid decisions. Pre-assign: CFO (A), Legal (R), Risk (R), Business Continuity (C).

Frequently Asked Questions

How do we handle RACI conflicts when two departments disagree on vendor ownership?

Document the conflict and escalate to the lowest common executive. Most conflicts stem from unclear tier definitions—spend time defining exact criteria for Tier 1/2/3 vendors.

Should our RACI matrix change based on vendor spend levels?

Yes. Vendors over $1M annual spend typically need CFO involvement (Consulted or Accountable). Vendors under $50K can use simplified RACI with fewer stakeholders.

How often should we review and update our TPRM RACI matrix?

Quarterly for the first year, then semi-annually. Trigger immediate reviews after major incidents, organizational changes, or when onboarding time exceeds SLA by 50%.

Can one person hold both Accountable and Responsible roles?

Only for Tier 3 vendors or during initial program development. For Tier 1-2 vendors, separate A and R roles to ensure proper oversight and avoid conflicts of interest.

How do we implement RACI for vendors that span multiple business units?

Designate a primary business unit owner as Accountable, with other units as Consulted. For true enterprise vendors, consider creating a vendor steering committee with rotating accountability.