GV.SC-02: Cybersecurity roles and responsibilities for suppliers, customers, and partners are established, communicated, and coordinated internally and externally

To meet GV.SC-02, assign clear cybersecurity roles and responsibilities across third parties (suppliers, customers, and partners), document them in contracts and operating procedures, and run a coordination cadence so internal teams and external contacts execute consistently during onboarding, change events, and incidents. Treat this as a governance control with auditable ownership and recurring evidence.

Key takeaways:

• Define “who does what” for third-party security across the full lifecycle: onboard, operate, change, offboard, incident.
• Put responsibilities where they will be used: contract clauses, RACI, runbooks, and escalation paths shared internally and externally.
• Prove coordination with records: contact lists, meeting notes, incident tickets, contract redlines, and test results.

GV.SC-02: cybersecurity roles and responsibilities for suppliers, customers, and partners are established, communicated, and coordinated internally and externally requirement is a governance requirement that closes a common operational gap: everyone assumes someone else is responsible for third-party security until an incident or audit forces clarity. NIST CSF 2.0 makes this explicit under the Governance function, Supply Chain category: you need defined roles, you need to communicate them, and you need to coordinate them across organizational boundaries ¹.

For a CCO, Compliance Officer, or GRC lead, the fastest path to operationalizing GV.SC-02 is to treat it like an accountability system, not a policy statement. That means: (1) naming control owners and backups internally, (2) defining third-party-facing roles (security contact, incident liaison, privacy contact, vuln disclosure contact), (3) embedding responsibilities into third-party agreements and playbooks, and (4) running a repeatable coordination process with evidence you can hand to auditors.

The goal is not paperwork. The goal is fast, predictable execution when something changes: a new critical supplier, a customer integration, a partner API, a breach notification, or a major control failure.

Regulatory text

Excerpt (GV.SC-02): “Cybersecurity roles and responsibilities for suppliers, customers, and partners are established, communicated, and coordinated internally and externally” ².

Operator translation (what you must do):

1. Established: Define specific cybersecurity responsibilities for internal functions and for each third-party relationship type (supplier, customer, partner).
2. Communicated: Make those responsibilities available to the people who must execute them (procurement, legal, engineering, SOC, incident response, account teams) and to the third party’s points of contact.
3. Coordinated: Run a working mechanism (cadence + triggers + escalation paths) so responsibilities are executed across boundaries during normal operations and during incidents.

If you cannot show who owns third-party security outcomes and how you coordinate with third parties during real events, you have not met GV.SC-02 in a defensible way ¹.

Plain-English interpretation of the requirement

GV.SC-02 requires a “role clarity system” for third-party cybersecurity. Auditors and regulators rarely accept “the vendor is responsible” or “our security team handles it” unless you can point to contract language, a RACI, and operational artifacts that prove it works.

What “roles and responsibilities” should cover in practice:

• Due diligence and onboarding: who reviews security documentation, who approves risk exceptions, who signs off on residual risk.
• Ongoing assurance: who monitors issues, who collects recurring evidence, who validates remediation.
• Access and integration: who approves connectivity, who manages credentials/keys, who reviews data flows.
• Incident management: who notifies whom, within what timeframe (contractual), and who coordinates containment and customer communications.
• Change management: who must be notified when a third party changes hosting, subprocessors, controls, or architecture.
• Offboarding: who ensures access removal, data return/deletion, and final attestations.

Who it applies to

Entity scope: Any organization operating a cybersecurity program that depends on third parties for technology, business processes, data processing, manufacturing, logistics, professional services, or customer/partner integrations ¹.

Operational context where this becomes urgent:

• You have critical suppliers (cloud, MSSP, payroll, ERP, payments, software dependencies).
• You exchange sensitive data with customers or act as a data processor.
• You run partner ecosystems (resellers, integration partners, OEM agreements, referral programs).
• You have distributed ownership (procurement buys, IT integrates, Security monitors, Legal contracts), creating accountability gaps.

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

1) Define a third-party cybersecurity RACI (internal)

Build a RACI that is specific enough to run. Minimum rows to include:

• Third-party intake and classification (criticality, data type, connectivity)
• Security due diligence and risk rating
• Contract security terms ownership (who negotiates, who approves exceptions)
• Integration/security architecture review
• Recurring assurance (SOC reports, pen tests, SIG/CAIQ, questionnaires)
• Subprocessor/4th-party management review
• Incident notification intake, triage, and coordination
• Termination/offboarding security steps

Assign: Responsible, Accountable, Consulted, Informed for each row to named roles (not departments). Store it in your GRC system or controlled document repository.

2) Establish third-party-facing roles (external)

For each critical third party relationship, identify and record:

• Your Security contact (or third-party risk manager)
• Your Incident response liaison (24/7 if applicable)
• Your Privacy contact (if personal data is involved)
• Your Legal/contracts contact
• Your Technical owner (system owner / integration owner)

Then obtain the equivalent contacts from the third party and validate they are operational (not a generic inbox that no one monitors).

3) Embed responsibilities into contracts and operating procedures

Translate the RACI into enforceable and executable language:

• Contract exhibits / security addendum: incident notification and cooperation duties, access control expectations, audit/support obligations, subprocessor rules, data return/deletion, and escalation paths.
• Operating procedures: third-party onboarding SOP, security review checklist, exception workflow, and incident runbook steps that reference the external contacts.

You are aiming for alignment: the contract sets obligations; the SOP shows how your teams execute them; the runbook shows how you coordinate under pressure.

4) Create a coordination cadence and triggers

Define coordination as a process with a schedule and event triggers:

• Cadence: periodic touchpoints for critical third parties (security review meetings, risk reviews, change review).
• Triggers: security incidents, major control failures, material architecture changes, new subprocessors, new data types, new network connectivity, merger/acquisition, or a high-risk audit finding.

Record meeting notes, actions, and owners. If you cannot sustain meetings, use ticket-driven coordination (but make it consistent and exportable).

5) Operationalize incident coordination across organizational boundaries

Implement an external incident coordination “minimum viable mechanism”:

• A maintained external contact directory mapped to third-party criticality
• A notification intake method (email alias + ticketing + on-call rotation)
• A runbook for engaging third parties (containment requests, evidence requests, status cadence, customer notification support)

Test this with tabletop exercises that include at least one third-party participant for critical relationships. Capture outcomes and action items for follow-up ¹.

6) Map GV.SC-02 to owners and recurring evidence

Treat GV.SC-02 as a control with:

• Control owner (Accountable)
• Evidence owner (Responsible for collection)
• Evidence frequency tied to lifecycle events and a recurring cadence

Daydream (or any GRC system) becomes useful here because it can keep the RACI, contract artifacts, third-party inventory references, and evidence requests tied to the requirement, so audits become retrieval work instead of archaeology ³.

Required evidence and artifacts to retain

Keep artifacts that show definition, communication, and coordination:

Definition

• Third-party cybersecurity RACI (version-controlled)
• Third-party risk management policy/procedure sections assigning accountability
• Role descriptions for key owners (security, procurement, legal, system owners)

Communication

• Onboarding packets or internal SOP links distributed to stakeholders
• Contract templates / security addendum language and executed agreements
• External contact directory shared with relevant internal teams and stored centrally

Coordination

• Meeting minutes, action logs, and risk review outputs for critical third parties
• Tickets showing escalation and cross-company coordination (incidents, vulns, changes)
• Tabletop exercise records that include third-party participation (invite list, scenario, outcomes)
• Exception approvals with approver identity and conditions

Common exam/audit questions and hangups

Auditors tend to probe four failure modes:

1. “Show me the owner.” Who is accountable for third-party cybersecurity governance, and who is accountable for a specific critical supplier relationship?
2. “Where is it written?” Do contracts reflect the operational responsibilities you claim exist?
3. “How do you coordinate in an incident?” Provide the runbook and evidence from a real incident, a tabletop, or a simulated escalation.
4. “How do you keep it current?” Contact lists rot fast. Auditors ask how you validate and update third-party roles and contacts.

Hangup: teams present a policy but cannot produce executed agreements, a current contact list, or coordination evidence. That typically reads as “designed, not operating.”

Frequent implementation mistakes and how to avoid them

• Mistake: RACI exists but is generic. If it doesn’t name roles that map to your org chart and workflows, it won’t run.
  Avoid: write the RACI from your intake-to-offboarding process map, then assign named roles.

• Mistake: Contracts say one thing; operations do another. Example: contract says “notify within X,” but your incident runbook doesn’t include external notification steps.
  Avoid: cross-walk contract clauses to runbook steps and create a single escalation directory.

• Mistake: Treating customers and partners as “not third parties.” Many orgs only apply controls to suppliers.
  Avoid: include customer integrations (shared responsibility) and partners (joint go-to-market, shared systems) in the same role clarity model.

• Mistake: No coordination triggers. You wait for annual review while integrations and subprocessors change monthly.
  Avoid: define triggers tied to technical changes, data changes, and incident signals.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so do not treat this page as enforcement analysis.

Operational risk is still concrete: unclear responsibilities create delayed incident response, missed notifications, uncontrolled access paths, and contract disputes during breaches. GV.SC-02 is designed to prevent that by forcing accountability and coordination ¹.

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Build a list of your critical third parties (start with those handling sensitive data or having network access).
• Draft the third-party cybersecurity RACI covering onboarding, assurance, incident coordination, and offboarding.
• Create a single external contact directory template and start populating it for critical relationships.
• Identify contract gaps for incident notification, cooperation duties, and escalation paths; open legal/procurement tickets.

Days 31–60 (Near-term)

• Publish internal SOP updates: intake checklist, security review workflow, exception approvals, and incident coordination steps.
• Update contract templates and start retrofitting critical agreements as they renew or change.
• Run one coordination exercise: a tabletop scenario that requires contacting at least one third party and exchanging status updates.

Days 61–90 (Operationalize and prove)

• Implement a recurring evidence routine: contact validation, critical third-party reviews, and exception follow-ups.
• Tie artifacts to GV.SC-02 in your GRC system for retrieval (RACI, contracts, meeting notes, tickets, exercises).
• Report to leadership: top coordination gaps, overdue contract fixes, and the current state of third-party contact readiness.

Frequently Asked Questions

Do we need a separate RACI for suppliers vs customers vs partners?

You can use one RACI framework, but you should define role variants by relationship type (supplier, customer, partner) because incident duties and shared responsibility differ. Keep the structure consistent so audits and operations don’t fragment.

What counts as “communicated” to third parties?

Communication is defensible when it is explicit and retrievable: executed contract clauses, shared escalation paths, and named points of contact. A verbal understanding is fragile and hard to prove.

How do we handle shared responsibility in customer environments (for example, SaaS deployed into customer cloud)?

Document the boundary in writing: which party configures controls, who monitors logs, who patches which layer, and who notifies on detection. Put it in an integration guide and reference it in the contract or order form.

How current does the third-party contact directory need to be?

Set a validation trigger based on your risk tiering and lifecycle events. The key is consistency: demonstrate you validate contacts on a defined cadence and after material changes.

What evidence is strongest if we haven’t had an incident involving a third party?

A tabletop exercise that includes third-party participation plus ticket evidence of contact verification and contract alignment is usually the cleanest substitute. Keep the invite, scenario, outcomes, and action tracking.

Where does Daydream fit without turning this into a tool exercise?

Use Daydream to map GV.SC-02 to a control owner, store the RACI and third-party contact directory, and schedule recurring evidence requests tied to your third-party inventory. That reduces audit prep time and keeps coordination artifacts from living in scattered inboxes.

Footnotes

1. NIST CSWP 29

2. NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes

3. NIST CSF 1.1 to 2.0 Core Transition Changes