System and Organizations Controls (SOC) reporting comes in multiple varieties, with each kind applying to different industries or intended for different audiences. SOC 2 is primarily aimed at Software-as-a-Service (SaaS) providers and similar service organizations. Although SOC 2 compliance provides a comprehensive framework for security, data integrity, user privacy, and more, there are some issues that can only be identified with a SOC 2 gap assessment.
The Importance of Analyzing Security Gaps
A SOC 2 gap analysis is a great way of uncovering shortcomings you may have missed during your initial SOC 2 implementation. Whether you’re specifically preparing for an audit, recovering from an adverse audit, or just want to make sure you’re meeting all compliance requirements, these assessments ensure a smooth SOC 2 implementation across the board.
Successful SOC 2 gap assessments require knowledge of the following:
- The Trust Services Criteria (TSC), which provide the framework for compliance
- The SOC 2 “themes,” comprising four categories for organizing some of the SOC 2 safeguards
- SOC 2 gap assessment focal points, which streamline analysis on critical factors
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The SOC 2 Trust Services Categories
Modern SOC 2 reports revolve around five distinct trust service categories. Each provides general measures and rubrics by which to assess security, relative to established targets (i.e., the individual criteria comprising the TSC:
- Data security – Measures for physical security, such as for data centers and hardware, along with logical or virtual safeguards, such as for networks, profiles, and software
- System availability – Measures for controls that ensure systems’ accessibility, since an inaccessible system or other forms of downtime are bottlenecks for the entire organization
- Processing integrity – Measures to ensure uniformity and consistency across data processing procedures, relative to their intended and communicated purposes
- Data confidentiality – Measures for data privacy concerning all information (not just personal information), relative to applicable rules, laws, regulations, or expectation
- User privacy – Measures specific to personal and personally identifiable information (PII), rather than all sensitive data. Data may fall under Privacy and Confidentiality
Any organization missing elements pertaining to these categories or TSC adherence and implementation are easily remediated following a SOC 2 gap assessment. Rather than risk receiving poor results on an official evaluation, it’s wise to conduct gap and readiness assessments prior to a full-fledged SOC 2 Type 1 or 2 audit.
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The TSC
SOC 2 assessments evaluate the implementation of and adherence to the TSC (both common and supplemental) and the security safeguards stipulated within. The “common” criteria (CC) equally apply to the initiatives put forth within the five categories listed above. Additionally, each category (aside from Security) is aligned with one the four “supplemental” criteria series.
Individual supplemental criteria series are designated within the framework by acronyms respecting the Categories (i.e., A, PI, C, and P).
The SOC 2 Supplemental “Themes”
In addition to aligning the TSC’s supplemental criteria with the five categories, they are organized according to four themes:
- Logical and physical access controls
- Systems and operations
- Change management
- Risk mitigation
To maintain alignment between strategic goals and technical implementations, it’s crucial to keep these themes in mind when preparing for and conducting a SOC gap analysis.
Logical and Physical Access Controls
These controls facilitate logical and physical access to data, including data storage, processing, and transmission. Many of these controls fulfill the needs of the first category—data security—but they also provide some amount of coverage for data confidentiality and user privacy.
The CC6 Series in the TSC delineates all such controls, which pertain to hardware and software such as:
- Large-scale datacenters
- Severs, workstations, and storage devices
- Antivirus software
- Firewalls and network monitoring tools
- Data backup and archival systems
- User access and authentication
System and Operations
Meant to guide day-to-day operations and maintain overall system health, these controls help maintain widespread system availability and processing integrity through top-down management. In the TSC, these appear across the CC7 Series, delineating measures for efficient operations.
Notably, issues with these controls can potentially impact all others, such as logical and physical access or change management, along with overall cyberdefense posture.
It’s critical to prioritize management and oversight in your SOC 2 gap assessment.
Change Management
Due to the dynamic nature of data processing and the rapid evolution of IT overall, change is inevitable. These controls—delineated across the TSC’s CC8 Series—provide a standardized approach to change management to facilitate the integration of new technologies and migration between varied IT and security systems. It comprises best practices for regular and special assessments, such as quarterly asset scans and supplemental tests upon asset onboarding.
Don’t forget to address this issue during your SOC 2 gap analysis; it’s easily overlooked.
Risk Mitigation
The final set of “themes” is focused on mitigating risks before they actually happen.
Risk mitigation pertains to all five TSCs and comprises numerous strategies of its own; most of these require robust visibility infrastructure to detect risks, then identify, analyze, prioritize, and address them accordingly. Therefore, SOC 2 gap assessment should consider infrastructure related to:
- Vulnerability management – The capacity to identify vulnerabilities, or weaknesses in IT and security infrastructure that could be exploited by threats (e.g., weak firewalls)
- Third party risk management – Concerted efforts to account for, identify, communicate, and address threats and vulnerabilities specific to strategic partners (e.g., vendors)
- Threat detection – The capacity to scan for, detect, identify, categorize, and strategize mitigation for varied threats (e.g., ransomware, denial-of-service (DoS) attacks)
- Penetration testing – Deep analysis comprising simulated attacks and detailed study of how the tester infiltrates systems, geared toward remediating all identified weaknesses
This is an exhaustive list, and these tools should be mixed and matched to find the best solution for your organization’s needs—both for SOC 2 compliance and risk mitigation more broadly.
Optimal SOC 2 Gap Assessment Focal Points
Understanding the SOC 2 TSCs and the basic controls will help steer your SOC 2 gap assessment strategy. While it’s important to focus on the specific gaps pertinent to your organization, most start by double-checking for common gaps and shortcomings, such as:
Risk Management
Organizations need to execute a holistic risk management strategy over performing basic and reactive mitigation.
A system should be in place that proactively works to reduce the volume and severity of risks, rather than just responding to them as they appear. Internal and external penetration testing, paired with regular vulnerability assessments, will help uncover network-specific and third-party risks.
It’s also helpful to classify risks according to their general area of impact. Further categorizing them according to severity helps prioritize risks that pose the biggest threat. Feel free to use as many different categories as needed, but some common classifications include:
- Organizational risks
- Financial risks
- Legal and regulatory risks
- Reputation and branding risks
Business Continuity
When planning a cybersecurity program, you should expect the best but plan for the worst. This is the driving concept behind business continuity planning, and it can help you through nearly every phase of SOC 2 gap analysis and compliance. Assume that attacks and other events will happen—a question of when rather than if—and be prepared to stay secure in spite of them.
Business continuity planning provides a clear protocol for maintaining business-as-usual, or as close to usual as possible, during an IT incident. Establishing departmental leaders and lines of communication, designating data backup systems, and prioritizing remediation activities are all part of business continuity planning. The benefits extend far beyond SOC 2 audits and reports.
Network Monitoring
Organizations should optimize their network visibility and monitoring in preparation for a SOC 2 audit. Since there are plenty of automated tools available for networking monitoring and threat detection, along with expert-driven strategies, many gaps in network security are easy to detect.
However, those that aren’t can be among the most insidious security threats to an organization.
Most cloud platforms, including AWS, Microsoft Azure, and Google Cloud Platform, integrate network monitoring tools explicitly built for the cloud to best ensure optimal protection. If your organization uses the cloud, ensure these safeguards are in place and, if needed, adjust the settings to meet your specific needs. Depending on your defined goals, or expectations of business partners, your SOC 2 gap assessment may identify ways in which these built-in controls are not adequate.
Policy Management
Many of the concepts in SOC 2 are relative, depending on organizationally-defined objectives.
SOC 2 gap analysis should identify any areas where organizational policy fails to identify its objectives clearly or sets systems up for failure with confusing definitions or protocols. Look specifically at the ways in which organizational policies govern or impact the following:
- Information security – Rules for how, where, why, and by whom data is processed
- Change management – Rules governing procedures before, during, and after changes
- Password management – Rules for user authentication and account management
Any inconsistencies in these policies can lead to major security risks beyond SOC 2 reports.
Vendor Management
Gaps within the security systems of your third-party vendors pose serious risks to your organization. To minimize and avoid these gaps, ensure you’re working with legitimate vendors and suppliers at all times. You can make the process selection easier by asking questions like:
- Is the audit performed by a qualified professional? Only independent CPAs (Certified Public Accountants) and accountancy organizations are permitted to perform SOC 2 compliance auditing.
- Is your team familiar with IT? Since SOC 2 is primarily meant for IT service providers, it’s crucial to find an auditor with a background in IT.
- How long have you been in business? The various levels of SOC reporting and auditing have existed for years. For best results, try to find an auditor with as much experience as possible.
- What happens if I have an adverse audit? While organizations can’t fail a SOC audit, they can receive an adverse rating. Clarifying any follow-up actions prior to the audit will help your team know what to expect in the worst-case scenario.
- Do you provide SOC 2 gap assessment or audit preparation? Some organizations provide assistance before and after a SOC 2 audit. These can often spot shortcomings that were missed in earlier examinations and advise their remediation.
Physical and Logical Security
Holes within your physical security are easily identified with a comprehensive SOC 2 gap assessment. Physical safeguards to prioritize include, but are not limited to, the following:
- Ongoing video surveillance – Use video surveillance to track the movement of people—both invited and uninvited—throughout your facilities. Digital video recordings should be kept for a minimum of 30 days before deletion.
- Employee identification – Small organizations won’t have a problem tracking or verifying employees, but it’s a real possibility for larger organizations. Eliminate imposters with proprietary employee ID cards or radio frequency interference (RFI) devices.
- Visitor logging and verification – Require any guests or visitors to register with on-site security prior to entering any facility. Use traditional photo ID to verify each individual’s identity.
- Employee background checks – If you’ve fallen victim to disgruntled employees and malicious insiders, you’ll want to improve the consistency and effectiveness of criminal history searches and background checks.
Holes in logical or virtual security also have numerous remediation strategies. Sound policy is the best place to start, but a more programmatic approach may be more impactful. Consider:
- Data encryption – Rendering files inaccessible, even if stolen. Experts recommend 128-bit encryption minimum, but 192- and 256-bit encryption algorithms are used, too.
- Multifactor authentication (MFA) – Requiring at least two factors (e.g., something the individual knows, something they possess, and something they are) for authentication.
- Training and education – Comprehensive, organization-wide training to be conducted during onboarding, at regular intervals, and as needed (e.g., after an attack).
Secure Documentation
In many cases, SOC 2 gap assessments hinge upon the recordkeeping and safekeeping of critical records. Whether digital or hardcopy, detailed documentation helps you track any recurring issues, follow new system implementations, and maintain compliance on a long-term basis.
To achieve the best results during your SOC 2 gap analysis, ensure the presence of:
- Data security and integrity records, including incident reports and past remediations
- Inventory of assets, including physical and logical (virtual) ones
- Policies and procedures regarding human resources, including protocols for onboarding, performance evaluation, and termination
- Standard operating procedures regarding daily operations, business continuity, disaster recovery, and more
Sealing Your SOC 2 Gaps
Gaps in SOC 2 compliance can lead to adverse audits and regulatory fines while increasing your risk of experiencing a cyberattack.
Take the time to perform a comprehensive SOC 2 gap assessment and contact RSI Security today for even more information on how you can achieve and maintain full SOC 2 compliance.