Safeguard 15.6: Monitor Service Providers

Most third-party risk failures happen after contracting. The provider changes a subprocess, subcontracts work, misses patching expectations, or suffers an incident, and the customer only learns about it through an outage or breach. Safeguard 15.6: monitor service providers requirement addresses that gap by pushing you to treat third parties as part of your operational environment, with ongoing visibility and follow-up, not a one-time due diligence checkpoint (CIS Controls v8; CIS Controls Navigator v8).

For a Compliance Officer, CCO, or GRC lead, the fastest path to implementation is to translate “monitor” into a repeatable control: an inventory of in-scope providers, a monitoring plan based on criticality, clear triggers (incidents, major changes, audit report updates, SLA misses), and a workflow that produces durable evidence. If you can show (1) what you monitored, (2) when you monitored it, (3) what you found, and (4) what you did about it, you are operating the safeguard in a way auditors can validate.

This page gives requirement-level guidance to get that system running with minimal theory and maximum exam readiness.

Requirement: Safeguard 15.6 — Monitor Service Providers

Safeguard 15.6 expects you to keep watch over service providers throughout the relationship lifecycle and respond to changes that alter risk. You are proving that security and resilience expectations are still being met post-contract, and that gaps lead to action (CIS Controls v8; CIS Controls Navigator v8).

Plain-English interpretation

“Monitor service providers” means:

• You maintain ongoing assurance that service providers continue to meet the security requirements you set at onboarding.
• You detect and respond to material changes (scope, systems, subprocessors, locations, control failures, incidents).
• You create a traceable record of reviews, findings, decisions, and remediation (CIS Controls v8; CIS Controls Navigator v8).

Monitoring includes both planned activities (scheduled reviews) and event-driven activities (triggered by incidents or change).

Who it applies to

Entity scope

• Any enterprise or technology organization that relies on service providers for systems, data processing, hosting, support, development, security tooling, or business operations (CIS Controls v8; CIS Controls Navigator v8).

Operational context (what counts as a “service provider”) Include third parties that:

• Store, process, transmit, administer, or can access your data (including metadata and logs).
• Provide infrastructure or platforms (cloud, colocation, managed services).
• Provide security-relevant services (MDR, SOC, vulnerability scanning, identity services).
• Affect availability or integrity of critical business processes (payments, customer support platforms, ERP, payroll).

Exclude (or monitor lightly) providers with no meaningful access or impact, but document the rationale. Auditors do not need everything to be “high touch,” but they do expect consistent triage logic.

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Regulatory text

Framework excerpt (provided): “CIS Controls v8 safeguard 15.6 implementation expectation (Monitor Service Providers).” (CIS Controls v8; CIS Controls Navigator v8)

What the operator must do Translate the excerpt into three operator obligations you can defend in an assessment:

1. Define monitoring for service providers (what signals you look at, how often, and who is responsible).
2. Perform the monitoring on an ongoing basis for in-scope service providers.
3. Retain evidence that monitoring happened and that issues were tracked to resolution (CIS Controls v8; CIS Controls Navigator v8).

If you cannot produce recurring artifacts, the control will read as “designed but not operating.”

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What you actually need to do (step-by-step)

Step 1 — Set scope and tiers (so monitoring is proportional)

Create a service provider register (or extend your third-party inventory) with:

• Provider legal name and service description
• Business owner and technical owner
• Data types involved (customer data, employee data, credentials, logs)
• Access method (API, VPN, SSO, direct console access)
• Criticality tier (critical/high/medium/low)
• Contract start/end and renewal date
• Subprocessor allowance and notification requirements

Practical tiering rule: tier primarily on data sensitivity, privileged access, and availability impact.

Step 2 — Define your monitoring plan (cadence + triggers)

For each tier, define:

• Planned review cadence (your policy choice; set something you can sustain)
• Required assurance inputs, such as:
  • Latest independent audit report or equivalent assurance package (if applicable)
  • Security incident notifications and post-incident reports when relevant
  • SLA and uptime reports (where availability matters)
  • Pen test summaries or vulnerability management attestations (where appropriate)
  • Subprocessor change notices (where contract permits)
• Event-driven triggers, such as:
  • Reported incident at the provider
  • Major service change, migration, or architecture change
  • New subprocessor, new region, or change in data handling
  • Repeated SLA misses or support degradation
  • Contract renewal/expansion (scope increase)

Your monitoring plan is what turns “monitor” into something testable.

Step 3 — Assign ownership and workflow

Monitoring fails most often due to unclear ownership. Set:

• Third-party risk function (GRC/TPRM): runs the program, chases artifacts, manages workflow
• Business owner: confirms service scope, validates SLA/business impact, approves risk decisions
• Security owner: reviews security artifacts, logs risk issues, defines required remediation
• Procurement/Legal: enforces contract rights (notice, audit, incident terms) and tracks renewals

Use a ticketing or GRC workflow so every monitoring cycle produces a record.

Step 4 — Collect recurring assurance and operational signals

Run monitoring as a repeatable cycle:

1. Request/collect new assurance artifacts based on tier and triggers.
2. Review against your baseline requirements (security addendum, data processing terms, SLA).
3. Record findings in a standard template (pass/concern/fail; exceptions; compensating controls).
4. Open issues with due dates and owners when gaps exist.
5. Escalate when risk exceeds tolerance (e.g., unaddressed critical findings, repeated incidents).
6. Close issues with evidence of remediation or documented risk acceptance.

Where you have technical telemetry (for example, CASB/SaaS security posture tools, cloud logs, or SSO access logs), connect it to provider monitoring for “live” signals. If you cannot, your control can still pass based on governance evidence, but real operational visibility reduces surprises.

Step 5 — Track changes and confirm contract compliance

Monitoring includes confirming the provider is honoring key terms:

• Incident notification timing and content ¹
• Data location/residency commitments (if applicable)
• Subprocessor approvals/notifications (if applicable)
• Right-to-audit / assurance delivery commitments
• Termination support: data return, deletion attestation, access removal

If a provider repeatedly fails contractual security obligations, document enforcement actions (formal notice, remediation plan, service credits, or termination decision).

Step 6 — Report up and tune the program

At an interval you can support, produce a roll-up for leadership:

• In-scope provider count by tier
• Monitoring completed vs planned
• Open issues by severity and age
• Exceptions/risk acceptances (who approved, renewal dates)
• Notable incidents and corrective actions

This creates a defensible governance loop and makes renewals less chaotic.

Where Daydream fits naturally: teams struggle with “recurring evidence capture.” Daydream is useful when you need monitoring schedules, artifact requests, and issue tracking to run automatically per provider tier, with audit-ready evidence bundles aligned to Safeguard 15.6 (CIS Controls v8; CIS Controls Navigator v8).

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Required evidence and artifacts to retain

Auditors will ask for proof of operation. Build an evidence binder ¹ containing:

Core artifacts (minimum viable)

• Third-party inventory/service provider register with tiering rationale
• Monitoring policy/standard describing cadence, triggers, roles, and escalation
• Monitoring plan matrix by tier (what you collect and review)
• Completed monitoring reviews (templates or tickets) showing date, reviewer, outcome
• Copies or references to assurance artifacts received during the period (as permitted)
• Issue log with remediation tracking and closure evidence
• Exceptions and risk acceptance memos with approvals and expirations

Useful supporting artifacts

• Renewal calendar with monitoring “gates” before signature
• SLA reports and incident communications
• Meeting notes for provider QBRs focused on security and resilience
• Subprocessor change notices and your approvals/assessments

Retention duration should match your internal policy and audit needs. The key is consistency and retrievability.

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Common exam/audit questions and hangups

Questions you should be ready to answer

• Which service providers are in scope for monitoring, and why?
• How do you determine monitoring depth and cadence by risk tier?
• Show monitoring evidence for a sample of critical providers.
• What triggers an out-of-cycle review?
• How do you track issues to closure and prevent repeat findings?
• How do you ensure contract terms support monitoring (audit reports, incident notice, subprocessors)?

Hangups auditors commonly flag

• A strong onboarding assessment but no post-contract monitoring records
• Monitoring done informally (emails/meetings) with no retained evidence
• No clear path from “finding” to “remediation,” only “noted”
• Incomplete inventory, especially SaaS adopted by departments

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Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating monitoring as an annual questionnaire only	Misses changes and incidents mid-year	Add triggers and require incident/change notifications in contracts
No tiering, same process for every provider	Program becomes unsustainable and then stops	Tier providers and right-size monitoring depth
Evidence scattered across inboxes	You cannot prove operation during an audit	Centralize in a GRC workflow or structured repository with naming standards
“Issues” without owners or deadlines	Findings never close	Require owner + due date + escalation path for overdue items
Ignoring subcontractors/subprocessors	Risk moves downstream without visibility	Track subprocessors for critical providers and require notifications
Monitoring doesn’t influence renewals	Business renews risky providers by default	Create renewal gates: monitoring completion and open-issues review before signature

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Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions.

Operationally, failure to monitor service providers raises predictable risk:

• Security risk: undiscovered control degradation, unreported incidents, unmanaged subprocessor exposure.
• Availability risk: repeated SLA failures and weak resilience planning can become business outages.
• Compliance risk: you cannot substantiate third-party oversight to customers, auditors, or regulators who ask for evidence of ongoing governance.

Treat the requirement as an assurance and evidence discipline. If you can produce records quickly, you reduce both incident impact and audit friction (CIS Controls v8; CIS Controls Navigator v8).

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A practical 30/60/90-day execution plan

First 30 days (stand up the control)

• Build or validate the service provider inventory; identify critical/high providers.
• Assign named owners (business + security + GRC) for each critical provider.
• Publish a monitoring standard: cadence, triggers, minimum required artifacts, escalation rules.
• Create templates: monitoring review form, issue log, risk acceptance memo.

By 60 days (run the first monitoring cycle)

• Execute monitoring for your highest-risk providers first.
• Collect current assurance artifacts and document reviews in your system of record.
• Open issues for gaps; assign owners and due dates; start remediation tracking.
• Add renewal gates so monitoring and open issues are reviewed before renewal.

By 90 days (stabilize and make it repeatable)

• Expand monitoring to the next tier of providers.
• Produce a leadership roll-up: monitoring completion, top issues, exceptions.
• Test retrieval: pick sample providers and assemble evidence packets end-to-end.
• Automate reminders, collection, and evidence packaging (this is where Daydream often reduces manual chasing and missed cycles).

Frequently Asked Questions

Does Safeguard 15.6 require continuous technical monitoring of a provider’s environment?

It requires ongoing monitoring of service providers, but the safeguard does not prescribe a specific technical mechanism in the provided excerpt (CIS Controls v8; CIS Controls Navigator v8). You can meet intent with governance-based monitoring plus technical signals where you have access.

Which providers should I monitor first if my inventory is incomplete?

Start with providers that host critical systems, handle sensitive data, or have privileged access. Document the scoping decision and run monitoring on that initial set while you complete the inventory.

What’s acceptable evidence if a provider won’t share detailed audit reports?

Keep what you can obtain and what your contract allows: an attestation letter, bridge letter, security whitepaper, or customer assurance package, plus your documented review and risk decision. If evidence is consistently unavailable, treat it as a risk and address it through contract changes or replacement planning.

How do I handle “no findings” reviews without looking like I rubber-stamped?

Record what you reviewed (artifacts, dates, scope) and what criteria you checked against, even if the outcome is “no issues identified.” A short review with clear inputs is stronger than a vague “approved.”

Do I need to monitor subcontractors/subprocessors directly?

Usually you monitor them indirectly through the primary provider’s obligations and notifications, unless the relationship is structured so the subprocessor is effectively your direct third party. Either way, track subprocessor changes for critical providers and document your response.

How should I operationalize this if procurement owns supplier management and security owns assessments?

Write a simple RACI and route work through one workflow so evidence lands in one place. GRC should be able to produce monitoring records without reconstructing them from multiple teams.

Footnotes

1. CIS Controls v8