Use this once to set up supplier risk management, then whenever a supplier is onboarded or its use changes. You get three files in a new folder, ./vendor-tiering/: a spreadsheet you can open in Excel listing every supplier with its scores, tier and next review (vendor-tiers.csv), a one-page note on how the tiers are decided, short enough for an owner to apply alone (tiering-method.md), and the questions each business owner must answer to confirm their suppliers' scores (questions-for-owners.md). This skill drafts for a human to review and sign; this skill never marks a control effective. The tier is a proposal; the business owner of each supplier confirms it.
Inputs to gather
Read the supplier list if one exists, the accounts payable export for the last twelve months, the single sign-on application list, the contract repository, the list of signed data processing agreements, the architecture overview and the business impact analysis if there is one. Ask the reader, in one message: which three services the company could not run without for a week, which teams buy software on cards or expenses, and whether any regulation in scope treats some suppliers specially (for example, services supporting critical functions of a financial entity).
Step 1: build the full population
Merge the sources and deduplicate by legal entity, not by product name. The supplier list alone is never complete. Add what finance pays, what single sign-on shows, what engineers call from code (hosting, email delivery, error tracking, analytics, AI models), contractors and agencies with access, and free tools where staff upload company or customer data; no spend does not mean no risk. Mark each row with where it was found.
Step 2: score three axes
Score each supplier on a three-level scale per axis and write one line of reasoning per score:
- Data: none or public (1); internal or limited personal data (2); customer data, confidential data, regulated data or personal data at scale (3).
- Access: none, or access only to the supplier's own service (1); user-level access into company systems or networks (2); privileged access, access to production, source code or the ability to change what customers receive (3).
- Dependency: replaceable within a week (1); replaceable within a month, or a key process degrades (2); critical, no fast alternative, outage stops revenue or a regulated service (3).
Add flags that do not change the score but drive extra work: processes personal data on the company's behalf, supports a function a regulation treats as critical, located or accessed outside the company's jurisdiction, and handles personal data or has privileged access with no signed agreement covering security and processing terms (an immediate action for the owner).
Step 3: tier by the highest axis
The tier follows the highest axis, never the average. A payroll provider with low dependency but sensitive data is still top tier.
- Tier 1: any axis at 3. Full due diligence: assurance reports, targeted questions, contract and data processing terms, exit plan. Reassessed every year.
- Tier 2: highest axis at 2. Assurance report or short questionnaire, contract terms checked. Reassessed every two years or on material change.
- Tier 3: all axes at 1. Register entry and terms checked at onboarding; reassessed on change.
Where a framework or regulation sets its own criteria for which suppliers need which treatment, run a framework lookup and record the mapping in tiering-method.md.
Step 4: sanity-check the result
In most companies tier 1 holds roughly 5 to 15 percent of suppliers. If half the list is tier 1, the axes are not being applied and assessment will collapse under its own weight; rescore with the owners. If a supplier the reader named as critical is not tier 1, one of the scores is wrong. Check for concentration: several tier 1 services on one provider is a risk worth one line in the method file. If the company publishes a sub-processor list, compare it with the flagged rows: a sub-processor missing from the spreadsheet, or a personal data supplier missing from the published list, is a defect to raise.
Step 5: write the outputs
The supplier spreadsheet (vendor-tiers.csv): supplier legal entity, service, source, business owner role, the three scores with reasons, flags, tier, assessment depth, last assessment date and method (report reviewed, questionnaire triaged, terms checked), next review. The method note (tiering-method.md): the scales, the tier rule and the cycle per tier, short enough for an owner to apply alone. Spell out what counts as a change that reopens a tier (new data category, wider access, new sub-processor, acquisition or breach at the supplier, use beyond the scored scope) and that the owner reports it. Propose an onboarding gate: no new tool receives company or customer data before it is scored and tiered. The owner questions (questions-for-owners.md): one block per owner with the scores they must confirm.
If the output folder exists, ask before overwriting and offer a new subfolder instead.
What good looks like
- The population is wider than the supplier list: free tools, code-level services and contractors are in it.
- Every score has a reason a business owner can confirm or correct in one line.
- The common mistake is tiering by spend. The tell: the expensive office software is tier 1 and the cheap error tracking tool that receives customer data in stack traces is tier 3.
- Averaging hides risk; the highest axis wins.
- Assessment effort per tier fits the hours the team actually has.
Framework lookups
If ISMS Copilot is connected to your agent (MCP server https://account.ismscopilot.com/v1/account/mcp), ask it the framework question with create_conversation (mode think, answer_format: decision) and keep one conversation for this task. Send only a short question in your own words, show it to the user first, and never include file contents, secrets, personal data or evidence. If it is not connected, check the official text of the framework yourself; this skill does not restate it. Set it up: https://www.ismscopilot.com/mcp?ref=grcskills-vendor-tiering
Rules
- MUST record the source of every supplier and the reason behind every axis score.
- MUST tier by the highest axis, never by spend or by an average.
- MUST write outputs only inside
./vendor-tiering/ and ask before overwriting.
- NEVER contact a supplier, send a questionnaire or change a contract.
- NEVER finalise a tier without the business owner's confirmation.
- NEVER put personal contact details of supplier staff into the outputs; use roles.