CYB-23 · Cyber security
Third-party cyber risk register — all material vendors assessed for cyber security posture
Most SA short-term insurance brokers depend on 3–6 shared technology platforms: a policy admin system (TIAL, Genius, Flexi), a comparator, insurer extranets, and a CRM. A compromise of any single vendor can expose every broker using that platform simultaneously. A formal third-party cyber risk register must document all vendors with access to client data, their assessed risk, and oversight controls.
Trigger
When this rule fires
No third-party cyber risk register; vendors with access to client PII not assessed; no cyber security clauses in vendor contracts; no exit plan for key vendors
Applicability gate
Confirm the entity's role before treating this as a duty
This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.
- Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
- Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
- Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.
Citation
Mapped source
This control maps to the public instruments below. The mapping does not establish entity applicability.
- Section
- Joint Standard 2 of 2024 — paragraphs 4.2.3, 7.2.3(a)(iii), 7.7.1(b) and 8.1.1(f) (third-party) / Joint Standard 1
- Legislation
-
- Joint Standard 2 of 2024
- Joint Standard 1 of 2023
- POPIA s.20-21
Remediation
How to close the gap
Compile a complete vendor inventory. Assess each vendor against a minimum cyber security questionnaire. Include cyber security obligations in all vendor contracts. Prioritise assessment of policy admin system and cloud providers.
Evidence required
Evidence to prepare if this control applies
- Third-party cyber risk register
- Vendor cyber security questionnaire (or equivalent assurance)
- Vendor contracts with cyber security clauses
- Periodic vendor review records
Automated assessment
Verified by the Provantis cyber scanner. Machine checks performed:
- VENDOR_CONCENTRATION