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03-C: Offshored Service Profile

This section assesses your organization’s use of offshored services and personnel, including where those services are performed, what data they can access, and how they are governed.

The questions are designed to clarify jurisdictions involved, data residency and transfer practices, and the security, privacy, and confidentiality controls applied to offshore teams and facilities. They also verify that offshored services are subject to the same or stronger standards, oversight, and incident management processes as onshore operations, so that location does not weaken overall risk posture.

Explanation: This question identifies whether client data or services are handled offshore, which may introduce additional risks such as weaker legal protections, lack of oversight, or different regulatory requirements.

Risks of Incorrect Answer: Exposure to jurisdictions with weaker data protection laws.

Difficulty enforcing data security or resolving legal disputes.

Potential non-compliance with U.S. data residency requirements.

Applicable Frameworks:

NIST CSF (ID.BE-4): Addresses the management of legal and regulatory requirements across jurisdictions.

GDPR (Art. 44-49): Regulates the transfer of personal data outside of the EU.

HIPAA (164.308(b)(4)): Requires business associate agreements, including offshore entities.

Explanation: Understanding the nature of offshore activities helps assess the potential impact on data security, compliance, and operational risks.

Risks of Incorrect Answer: Lack of transparency about offshore operations could lead to inadequate risk mitigation.

Services critical to the client’s business could face disruptions due to geopolitical instability or legal disputes.

Applicable Frameworks: ISO 27001 (A.15.1.1): Requires identifying and managing third-party risks.

SOC 2 (CC3.1): Requires identification of operational dependencies, including offshore services.

Explanation: This question helps determine the sensitivity of data handled offshore and the risk of data exposure or unauthorized access.

Risks of Incorrect Answer: Sensitive client data could be exposed to breaches or misuse due to insufficient offshore controls.

Non-compliance with regulations requiring strict control of specific data types (e.g., health data, financial data).

Applicable Frameworks: NIST CSF (PR.DS-5): Protects data at rest and in transit, including across borders.

HIPAA (164.310(b)): Requires safeguards for electronic protected health information (ePHI).

GDPR (Art. 5, 32): Ensures personal data is securely handled and protected.

Explanation: This ensures that offshore locations adhere to security policies and frameworks, reducing the risk of data breaches or operational failures.

Risks of Incorrect Answer: Offshore vendors might operate below the required security standard, exposing the client to vulnerabilities.

Regulatory non-compliance if the offshore location fails to implement necessary controls.

Applicable Frameworks: ISO 27001 (A.15.2.1): Ensures third parties comply with security standards.

NIST CSF (PR.IP-12): Establishes processes for managing third-party risks and security requirements.

SOC 2 (CC3.2): Assesses adherence to security principles at all locations.

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Some or all of the services described in this engagement may not be available to certain clients, including those who have affiliations or relationships with audit firms or related entities.

The information provided herein is of a general nature and is not intended to address the specific circumstances of any individual or entity. While we strive to offer accurate and up-to-date information, we cannot guarantee its accuracy at the time it is received or in the future. No action should be taken based solely on this information without seeking appropriate professional advice tailored to your particular situation. CRISP does not provide legal or tax advice.

This information is not intended to constitute “written advice concerning one or more Federal tax matters” as defined by section 10.37(a)(2) of Treasury Department Circular 230.

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