GV.SC-08: Relevant suppliers and other third parties are included in incident planning, response, and recovery activities

To meet gv.sc-08: relevant suppliers and other third parties are included in incident planning, response, and recovery activities requirement, you must identify which third parties are “relevant” to your critical services, then formally integrate them into your incident lifecycle through contracts, runbooks, contact paths, exercises, and recovery dependencies. Auditors will look for repeatable execution and evidence that third parties can support detection, response, and restoration. 1

Key takeaways:

  • Define “relevant third parties” based on service criticality and incident dependencies, not your full vendor list. 1
  • Update incident response and disaster recovery playbooks to include third-party roles, SLAs, communications, and technical procedures. 2
  • Retain proof: contracts, call trees, exercise results, post-incident reviews, and corrective action tracking that includes third parties. 1

GV.SC-08 is a supply chain governance requirement inside NIST CSF 2.0: you do not “do incident response” in isolation if your business relies on cloud providers, MSSPs, SaaS platforms, payment processors, data processors, logistics partners, or other external operators. The operational expectation is simple: if a third party can cause, detect, contain, or recover from an incident that impacts your organization, your incident planning must explicitly include them. 1

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat GV.SC-08 as a mapping exercise with hard deliverables: (1) a scoped list of relevant third parties tied to critical services, (2) contract language and contact paths that enable incident collaboration, (3) third-party-aware incident and recovery runbooks, and (4) evidence from exercises and real incidents that shows the process works. 2

This page gives requirement-level implementation guidance you can hand to Security, IT, Procurement, and the business. It is designed for audit readiness: clear control ownership, clear operating rhythm, and artifacts you can produce on request. 1

Regulatory text

Excerpt (GV.SC-08): “Relevant suppliers and other third parties are included in incident planning, response, and recovery activities.” 1

Operator meaning: You must (a) determine which third parties are relevant to incident outcomes, and (b) include them in the way you plan for incidents, respond to them, and restore services afterward. This is more than listing vendors in a policy. It requires practical integration: predefined communications, roles and responsibilities, technical procedures (forensics, log access, containment actions), and recovery dependencies (failover, data restoration, rebuild sequencing). 2

Plain-English interpretation (what “included” really means)

A third party is “included” when your teams can execute an incident workflow that depends on them without improvising:

  • You can reach the right third-party responders quickly (named roles, monitored channels, escalation).
  • You know what the third party will do versus what you must do (RACI clarity).
  • You have the contractual rights and technical access needed during an incident (logs, images, support, timelines).
  • Your recovery plan accounts for third-party restoration steps and constraints (service dependencies, data handoffs). 1

Who it applies to

Entity scope: Any organization operating a cybersecurity program and using external parties to deliver, support, or secure systems and services. 1

Operational contexts where GV.SC-08 becomes exam-critical:

  • Critical business services depend on SaaS, IaaS/PaaS, managed hosting, or data processors.
  • Security operations are outsourced (MSSP/MDR/SOC-as-a-service) or rely on external threat intel.
  • Regulated data flows through third parties (processors, sub-processors, fulfillment partners).
  • Your recovery model depends on third-party backups, DR sites, DNS/CDN, or payment rails. 2

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

1) Define “relevant third parties” using dependency-based criteria

Create a short, defensible definition and apply it consistently. Recommended criteria:

  • Service criticality: Third parties that support your critical services or crown-jewel processes.
  • Incident control points: Third parties that can detect, contain, eradicate, or recover (for example, they hold logs, control infrastructure, or run the platform).
  • Blast radius: Third parties that store/process sensitive data or connect to your networks.
  • Subcontracting: Key fourth parties (your third party’s critical subcontractors) where you have dependency risk. 1

Output: “Relevant Third Party Incident Integration List” with owner, service supported, and why it’s relevant.

2) Map third parties to incident scenarios and recovery dependencies

For each critical service, document:

  • Top incident scenarios where the third party is involved (outage, ransomware, data exposure, account takeover, pipeline compromise).
  • What you need from the third party in each scenario (evidence, containment actions, restore steps, status updates).
  • Timing expectations (e.g., notification windows you require, escalation speed, recovery sequencing). These are design targets; they become enforceable through contract language and operational testing. 2

Output: Dependency map embedded into service continuity plans and IR playbooks.

3) Update contracts so incident collaboration is possible

Procurement/legal changes are often the difference between a “paper control” and a workable one. For relevant third parties, ensure agreements cover:

  • Incident notification and coordination: who notifies whom, how, and what minimum content is required.
  • Access to evidence: logs, audit trails, forensic images (as applicable), and retention alignment.
  • Support obligations: availability during major incidents, escalation, and technical assistance.
  • Subprocessor visibility: requirements to disclose or manage critical subcontractors tied to the service.
  • Recovery commitments: restoration responsibilities, data return/portability, and assistance for transition if the provider fails. 1

Practical tip: Keep a “contract gap register” so you can show auditors you identified gaps and are driving remediation, even if not all contracts renew immediately.

4) Embed third parties into runbooks (IR + recovery)

Update your incident documentation so third parties are not an afterthought:

  • Incident Response Plan: add a section for “Third-Party Coordination” with triggers for engagement and decision authority.
  • Playbooks: include third-party steps per scenario (who contacts the provider, what to request, where to store evidence).
  • Comms plans: include third-party communications in your internal/external messaging logic (who approves, what channels).
  • Disaster Recovery / Business Continuity: list third-party prerequisites for recovery (DNS changes, vendor re-provisioning, license restores, key rotations). 2

Output: Updated runbooks with third-party-specific checklists and call trees.

5) Test it with exercises that include the third party

Tabletops that exclude the provider are weak evidence for GV.SC-08. Run exercises where at least one relevant third party participates (live or through validated procedures), and capture:

  • contact success,
  • time-to-triage with the third party,
  • clarity of roles,
  • evidence collection steps,
  • recovery sequencing and decision points. 1

Output: Exercise agenda, attendee list, injects, after-action report, corrective actions.

6) Operate the control on a recurring cadence

Set an operating rhythm:

  • review the “relevant third party” list when critical services change,
  • refresh contact paths,
  • validate contractual coverage for new providers,
  • track corrective actions to closure. 1

How Daydream fits naturally: Daydream is useful when you need a single workflow to map GV.SC-08 to an owner, link it to the third-party inventory, schedule recurring evidence collection, and keep contracts/runbooks/exercise artifacts together for audits.

Required evidence and artifacts to retain

Auditors typically want to see both design and operating evidence. Maintain:

  • Relevant third party list with rationale and service mapping.
  • Third-party incident communication matrix (contacts, escalation paths, channels).
  • Contract clauses or addenda covering incident notification, cooperation, evidence access, and recovery support.
  • Updated IR plan, playbooks, and DR/BCP procedures showing third-party steps.
  • Exercise artifacts (invites, attendance, scenarios, after-action reports, corrective action tickets).
  • Post-incident reviews referencing third-party performance and improvements. 1

Common exam/audit questions and hangups

Common questions you should be ready to answer with artifacts:

  1. “How do you define ‘relevant’ third parties, and who approves the list?”
  2. “Show a critical service and its third-party recovery dependencies.”
  3. “If your SaaS provider has an incident, how do you get logs and timelines?”
  4. “Where is this reflected in your IR plan and playbooks?”
  5. “Show evidence of testing that includes the provider, and how findings were remediated.” 1

Hangups that slow audits:

  • No clear scoping method, so the list looks arbitrary.
  • Contracts lack cooperation language, so procedures are aspirational.
  • Exercises happened, but third parties were not invited and no proxy evidence exists. 2

Frequent implementation mistakes (and how to avoid them)

Mistake Why it fails Fix
Including every vendor Creates noise, weakens focus on critical dependencies Scope to critical services and incident control points; document rationale. 1
Relying on a generic “notify vendor” step Fails under pressure; no evidence access or defined actions Add provider-specific checklists, contacts, and evidence requests. 2
Contracts silent on incident support Provider can refuse logs, timelines, or active assistance Add incident cooperation and evidence-access clauses at renewal; track gaps in a register. 1
DR plan ignores SaaS/managed services Recovery sequencing breaks because third-party dependencies are missing Document restore prerequisites, dependencies, and alternate procedures. 1
No corrective action closure Repeated findings; auditors see weak governance Track actions to closure with owners and evidence of completion. 1

Enforcement context and risk implications

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

Operationally, GV.SC-08 reduces two recurring failure modes: (1) response delays because you cannot reach the right third-party operators or obtain evidence, and (2) extended outages because recovery plans assume control you do not have in outsourced environments. Those failures also create reporting and customer-impact risk when incidents involve data processors or critical infrastructure dependencies. 1

Practical 30/60/90-day execution plan

Use these phases as an execution blueprint. Adapt scope to your environment and vendor footprint.

First 30 days (stabilize scope and ownership)

  • Assign a control owner for GV.SC-08 and name counterparts in Security/IT, Procurement, Legal, and BCM.
  • Draft “relevant third party” criteria and build the initial list mapped to critical services.
  • Create a third-party incident contact matrix for the in-scope third parties.
  • Identify contract gaps that block incident cooperation; start a gap register with renewal dates. 1

By 60 days (embed into runbooks and contracting motions)

  • Update IR plan and top playbooks to include third-party steps, evidence requests, and escalation paths.
  • Update DR/BCP documentation to include third-party recovery dependencies for critical services.
  • Socialize contract language updates with Legal/Procurement and incorporate into templates or addenda for new purchases. 2

By 90 days (prove operation with testing and evidence)

  • Run at least one exercise involving a relevant third party (or a validated proxy procedure if participation is not feasible).
  • Publish an after-action report and track corrective actions to closure.
  • Implement a recurring review cadence for: relevant third party list, contacts, contract gaps, and playbook updates.
  • Centralize evidence for audit requests; Daydream can help by tying GV.SC-08 to owners, tasks, and recurring evidence collection. 1

Frequently Asked Questions

How do I decide which third parties are “relevant” for GV.SC-08?

Start with critical services, then include third parties that host the service, process sensitive data, or control logs and recovery actions. Document the criteria and apply it consistently so your scope is defensible. 1

Do I need third parties to attend every incident tabletop?

No, but you need credible proof that incident workflows requiring third-party action are tested. For high-dependency providers, direct participation is the strongest evidence; otherwise keep documented procedures and contact tests that show you can execute. 1

What if a cloud/SaaS provider refuses to share logs or details during an incident?

Treat it as a contracting and architecture risk. Record the gap, negotiate evidence-access language at renewal, and adjust detection/response design so you have independent telemetry where feasible. 1

Does GV.SC-08 include fourth parties (my vendor’s vendors)?

GV.SC-08 is framed around suppliers and third parties that matter to your incident outcomes; in practice, that includes critical subcontractors when they materially affect your ability to respond or recover. Capture this via subprocessor transparency and dependency mapping. 1

What evidence do auditors ask for most often?

They typically want the scoped list of relevant third parties, runbooks that show third-party steps, contract language for incident cooperation, and exercise/after-action documentation with corrective action tracking. 1

How should GRC coordinate ownership between Incident Response and Third-Party Risk Management?

Assign clear accountability: IR owns execution of response and playbooks; TPRM/Procurement owns contracting and third-party inventory; BCM owns recovery planning. GRC ties them together through control mapping, evidence collection, and issue management. 2

Footnotes

  1. NIST CSWP 29

  2. NIST CSF 1.1 to 2.0 Core Transition Changes

Frequently Asked Questions

How do I decide which third parties are “relevant” for GV.SC-08?

Start with critical services, then include third parties that host the service, process sensitive data, or control logs and recovery actions. Document the criteria and apply it consistently so your scope is defensible. (Source: NIST CSWP 29)

Do I need third parties to attend every incident tabletop?

No, but you need credible proof that incident workflows requiring third-party action are tested. For high-dependency providers, direct participation is the strongest evidence; otherwise keep documented procedures and contact tests that show you can execute. (Source: NIST CSWP 29)

What if a cloud/SaaS provider refuses to share logs or details during an incident?

Treat it as a contracting and architecture risk. Record the gap, negotiate evidence-access language at renewal, and adjust detection/response design so you have independent telemetry where feasible. (Source: NIST CSWP 29)

Does GV.SC-08 include fourth parties (my vendor’s vendors)?

GV.SC-08 is framed around suppliers and third parties that matter to your incident outcomes; in practice, that includes critical subcontractors when they materially affect your ability to respond or recover. Capture this via subprocessor transparency and dependency mapping. (Source: NIST CSWP 29)

What evidence do auditors ask for most often?

They typically want the scoped list of relevant third parties, runbooks that show third-party steps, contract language for incident cooperation, and exercise/after-action documentation with corrective action tracking. (Source: NIST CSWP 29)

How should GRC coordinate ownership between Incident Response and Third-Party Risk Management?

Assign clear accountability: IR owns execution of response and playbooks; TPRM/Procurement owns contracting and third-party inventory; BCM owns recovery planning. GRC ties them together through control mapping, evidence collection, and issue management. (Source: NIST CSF 1.1 to 2.0 Core Transition Changes)

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