SOC 2 compliance ensures service providers meet client expectations for data security, and it offers the best value when implemented efficiently. To do so, organizations need to scope and install controls intentionally, prioritizing necessities for the specific kind of audit they’re targeting.
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An Optimal Path to SOC 2 Implementation
The System and Organization Controls (SOC) framework allows service organizations to meet the varying needs of prospective and existing clients across industries. Given the flexibility of the framework, it’s critical to seek out and execute a targeted, optimized assessment by:
- Scoping out what it will take to install and assess controls
- Installing SOC 2 Common Criteria controls that all audits require
- Implementing Additional Criteria controls required conditionally
- Preparing for a SOC 2 Type 1 or SOC 2 Type 2 audit (or both)
Working with a SOC implementation partner will ensure a seamless and efficient process.
Determining Implementation and Audit Scope
First, you’ll need to determine if you need a SOC 2 (or other kind of SOC) audit. The American Institute of Certified Public Accountants (AICPA) oversees three primary SOC frameworks:
- SOC 1 – Reporting on financial reporting controls (for technical audiences)
- SOC 2 – Reporting on Trust Service Criteria controls (for technical audiences)
- SOC 3 – Reporting on Trust Service Criteria controls (for general audiences)
The scoping process begins with a choice between SOC 1 and SOC 2 and/or 3. If you’re a financial services provider, you’re likely doing SOC 1, but you may also do SOC 2 and/or 3. If you’re any other kind of service organization, you’re likely doing one or both of the latter.
And, beyond choosing a SOC framework, there is also the question of Type. In a nutshell, SOC 1 and SOC 2 reports can be Type 1 or Type 2. Type 1 is a faster audit that commands fewer resources but provides less security assurance. Type 2 is a much longer ordeal that requires robust planning and allocation, but it provides the most security assurance to all stakeholders.
For more on the differences between what the prep for each Type looks like, see below.
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Which Controls Apply to Your Organization?
All kinds of SOC 2 reports and SOC 3 reports use the same control framework: the AICPA’s Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy (TSC). The TSC breaks down into nine sets of Common Criteria that apply to all assessments.
There are also Additional Criteria, organized under the Trust Service Principles or Categories named in the TSC’s full title. Each one (besides Security) comprises controls that may apply based on several factors, such as the particular kind of data your organization processes, the risks inherent to your environment, and whether your stakeholders request them specifically.
Ultimately, ensuring you install only those requirements you absolutely need to—and minimizing overlap with other regulatory and certification requirements—is a pillar of compliance efficiency.
Implementing Common Criteria Controls
Since the Common Criteria are required for all assessments, they are the best place to start.
Most of the AICPA SOC 2 criteria are derived from the foundational COSO framework. But some of them adhere more closely to COSO’s requirements. Within the Common Criteria or CC Series controls, the first five sets (CC1 – CC5) correspond directly to COSO principles. But CC6 – CC9 instead expand one COSO principle (#12, concerning policies for supplemental controls).
What this means in practice is that, within the baseline, you should prioritize even further. The first five CC series are not just first incidentally; allocating appropriate resources to meet them before moving on to other CC and Additional Criteria will minimize backtracking down the line.
Baseline Common Criteria Series
The first five series of SOC 2 Common Criteria requirements break down as follows:
- The Control Environment (CC1) – Top-line governance principles that establish clear responsibilities, from leadership down, to control and safeguard all sensitive systems.
- Communication and Information (CC2) – Controls ensuring accurate, reporting on status and activity across all systems, along with seamless communication thereof.
- Risk Assessment (CC3) – Fundamental infrastructure for identifying risks and risk factors (i.e., threats and vulnerabilities) and architecture for detecting them in practice.
- Monitoring Activities (CC4) – Controls for monitoring the functionality of all internal controls and safeguards, ensuring that they are updated and working as expected.
- Control Activities (CC5) – Governance principles ensuring that all controls selected contribute to organizational mission and goals by mitigating risks specific to them.
These are the most fundamental controls to prioritize as you begin your implementation.
Supplemental Common Criteria Series
The final four series of SOC 2 Common Criteria requirements break down as follows:
- Logical and Physical Access Controls (CC6) – Mechanisms governing how access to hardware, software, and other systems is restricted, provided, monitored, and controlled.
- System Operations (CC7) – Mechanisms for ensuring the smooth operation of systems that come into contact with sensitive data, including monitoring for and mitigating threats.
- Change Management (CC8) – Mechanisms for detecting changes to user data, along with ensuring that all changes are secure, authorized, and accounted for institutionally.
- Risk Mitigation (CC9) – Mechanisms for selecting and deploying mitigation strategies, and then escalating them as needed, to neutralize both potential and actualized threats.
These should be second priority (after CC1 – CC5) when implementing the SOC 2 framework.
Implementing Additional Criteria Controls
Beyond the Common Criteria, which alone suffice for Security, there are controls pertaining to the other Trust Services Categories—and these are not always required for every assessment.
The Additional Trust Services Criteria SOC 2 requirements break down as follows:
- Availability (A Series) – Controls ensuring systems are available for use by internal and external stakeholders and capable of meeting all organizationally defined objectives.
- Confidentiality (C Series) – Controls ensuring that other sensitive data (excluding personal data) is protected from improper use per organizationally defined objectives.
- Processing Integrity (PI Series) – Controls ensuring that processes enacted upon data are complete, accurate, timely, and authorized per organizationally defined objectives.
- Privacy (P Series) – Controls ensuring that sensitive personal data specifically is protected from unauthorized access or use, per organizationally defined objectives.
Depending on your circumstances, these may not need to be implemented. Check in with the stakeholder requesting a SOC 2 report (or a SOC 2 advisor organization) before installing them.
Preparing for a Type 1 or Type 2 Audit
As noted above, service organizations may choose to conduct a Type 1 or Type 2 audit for SOC 2 compliance. While they theoretically assess the same control implementation, they do so in radically different ways. This means that they are drastically different in scope, including the time they take to conduct and the overall resources that need to be marshaled for each.
Namely, a Type 1 audit is an expression of how your controls are designed. It is measured by examining the specific implementation as it exists at a particular point in time. A Type 2 audit is measured over a duration that typically lasts at least three months and often a year or more. In that span, controls are monitored holistically—it’s not enough for them to be installed properly; they also have to work and maintain complete functionality throughout the entire period.
What this means in practice is that you also need to prepare for the turnaround times.
Type 1 reports can theoretically be generated within a matter of weeks, whereas you’ll need at least six months’ time (if not much more) for a Type 2 report. So, many organizations opt to generate one or more Type 1 reports for stakeholders as they wait for full Type 2 results.
Other SOC Compliance Considerations
On the one hand, SOC 2 Type 2 is arguably the most efficient report despite its scale since it provides the highest level of security assurance in one go. But on the other hand, even with that optimal value, maximum efficiency might still look like generating multiple different SOC reports.
For example, many organizations that conduct a full Type 2 audit choose to produce both a SOC 2 report and a SOC 3 report. SOC 3 does not carry a “Type” designation but generally requires the same duration as a SOC 2 audit. You can prepare for both reports simultaneously and produce insights that can fuel B2B comms (SOC 2) alongside B2C marketing (SOC 3).
Additionally, there are other SOC frameworks tailored to specific industry niches. For example, AICPA publishes assessment protocols like SOC for Cybersecurity and SOC for Supply Chain.
Optimization may mean one report, or it may mean several all at once—or in quick succession.
Optimize Your SOC 2 Reporting Process
Conducting a SOC 2 audit, Type 1 or Type 2, can be daunting. Having a proper scope in place, minimizing the controls you install, and preparing for the specific Type of report you want all help to make the process more seamless—especially when working with a quality service provider.
RSI Security has helped countless organizations achieve and maintain SOC 2 compliance. We know that the right way is the only way to keep your stakeholders safe. We’ll help you rethink your cyberdefense approach to install and assess controls as swiftly and effectively as possible.
To optimize your process for meeting SOC 2 Trust Services Criteria, contact RSI Security today.
