System and Organization Controls (SOC) reports play a critical role in third-party risk management, with SOC 2 standing out as the go-to compliance framework for Software-as-a-Service (SaaS) providers and other service organizations. But even if your team has started down the road to SOC 2 readiness, there’s one step that can make or break your audit success: a SOC 2 gap assessment.
Before investing in a full Type 1 or Type 2 report, you need to be sure your systems are audit-ready. That’s exactly what a gap assessment can help you achieve.
Why a SOC 2 Gap Assessment Matters
A SOC 2 gap assessment identifies compliance weaknesses and security risks before they can impact your audit results—or your customers. Whether you’re preparing for your first audit or remediating issues from a previous one, the assessment acts as a diagnostic tool to uncover where your controls fall short of the Trust Services Criteria (TSC).
Here’s what an effective SOC 2 gap analysis should focus on:
- Alignment with the Trust Services Criteria (TSC)
- Coverage across key SOC 2 control groupings (Common Criteria)
- Critical areas like access control, risk management, and business continuity
Gap assessments ultimately ensure a smoother path toward full compliance and help future-proof your organization’s security posture.
Understanding the SOC 2 Trust Services Criteria (TSC)
SOC 2 evaluations revolve around the Trust Services Criteria, a set of principles developed by the AICPA to assess how well an organization protects sensitive data.
The five TSC categories are:
- Security: Logical and physical safeguards to prevent unauthorized access.
- Availability: Ensures systems are available and operational as agreed.
- Processing Integrity: Guarantees that systems process data accurately and as intended.
- Confidentiality: Protects sensitive business information from exposure.
- Privacy: Focuses on the handling of personally identifiable information (PII).
Security is the foundational category, and it’s always assessed in a SOC 2 audit. The other four are optional, depending on your services and customer expectations.
Key Control Groupings: Organizing the SOC 2 Criteria
The SOC 2 framework segments its control requirements into a series of Common Criteria (CC), which are grouped into practical operational themes to simplify implementation and auditing. These groupings align with the specific objectives of each Trust Services Criteria category and help organizations identify how their controls map to compliance.
A SOC 2 gap assessment should carefully evaluate each of these areas to identify missing or ineffective controls. Understanding the Common Criteria groupings helps ensure that your review is both comprehensive and structured.
1. Logical and Physical Access Controls (CC6 Series)
These controls ensure that only authorized individuals and systems can access sensitive information and infrastructure. They span physical protections and logical safeguards. Your gap assessment should investigate:
- User access provisioning and deprovisioning workflows
- Password strength and rotation policies
- Use and enforcement of multifactor authentication (MFA)
- Physical security protocols such as visitor tracking and ID verification
- Endpoint protection software (e.g., antivirus, antimalware)
- Network perimeter defenses including firewalls and intrusion detection systems
2. Systems and Operations (CC7 Series)
Operational controls focus on maintaining system health, availability, and responsiveness. Your assessment should confirm whether:
- Monitoring and logging tools are deployed across critical infrastructure
- Incident detection and alerting mechanisms are properly configured
- Incident response procedures are documented, tested, and reviewed
- Backup and recovery mechanisms are in place and regularly validated
- Systems are hardened and patched in a timely manner
3. Change Management (CC8 Series)
Change is inevitable in any IT environment. These controls ensure that updates, deployments, and system changes are managed securely to avoid unintentional risk exposure. Assess the following:
- Whether a formal change management process is documented and followed
- Approval and testing workflows for changes
- Version control practices for software and infrastructure code
- Emergency change procedures and rollback protocols
4. Risk Mitigation (CC9 Series)
These controls relate to identifying, prioritizing, and addressing risks. They are critical for both proactive and reactive defense. Your assessment should look for:
- A documented risk management framework that includes regular risk assessments
- Consistent vulnerability management, including scanning and patching
- Use of third-party risk assessments and vendor security evaluations
- Business continuity and disaster recovery plans with clearly assigned roles and responsibilities
- Metrics or KPIs to measure risk mitigation effectiveness
Focus Areas for Your SOC 2 Gap Assessment
To get the most out of your gap assessment, prioritize high-risk areas and commonly overlooked gaps. Here’s where to focus:
Risk Management
Effective programs proactively identify, classify, and prioritize risks. A mature risk management strategy should include:
- Internal and external pen testing
- Third-party risk analysis
- Risk classification (e.g., operational, financial, reputational)
Business Continuity Planning
A breach or outage is inevitable. How you respond matters more. Evaluate:
- Backup systems and data recovery protocols
- Communication plans and escalation procedures
- Role-based responsibilities during incidents
Network and System Monitoring
Robust visibility ensures you catch threats before they escalate. Assess:
- Use of automated tools (e.g., AWS CloudWatch, Azure Monitor)
- Centralized logging and alerts
- Cloud-specific monitoring configurations
Policy and Procedure Management
Clear, documented policies are essential for consistent and secure operations. Review:
- Access control and user behavior policies
- Change and patch management documentation
- Password and authentication policies
Vendor Risk Management
Third-party vendors introduce significant risk. Ensure your partners are secure by asking:
- Is the SOC audit performed by a qualified CPA firm?
- Does the auditor have IT and cybersecurity expertise?
- What remediation support is provided after an adverse finding?
Additional Assessment Areas
These additional focus areas extend beyond standard control categories and delve into the operational infrastructure and documentation practices that support a resilient security posture.
Physical and Logical Security
Address both tangible and digital entry points:
Physical Controls
- Surveillance systems
- Employee ID verification
- Visitor logs and access tracking
- Background checks
Logical Controls
- Multifactor authentication (MFA)
- Encryption (128-bit minimum recommended; 192- or 256-bit preferred)
- Role-based access controls
- Security awareness training
Documentation and Recordkeeping
SOC 2 auditors require robust documentation. Make sure your team maintains:
- Incident and remediation records
- IT asset inventories
- HR and operations policies
- SOPs for compliance-critical workflows
SOC 2 Gap Assessment: Close the Gaps, Strengthen Your Audit Readiness
Skipping a SOC 2 gap assessment means risking a failed audit or exposing your organization to security vulnerabilities. Conducting a thorough gap analysis ensures you’re not only prepared for the audit but also future threats.
Contact RSI Security today to schedule your SOC 2 gap assessment and take the first step toward full compliance.
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