Meeting the SOC 2 Trust Services Criteria ensures your organization aligns with client expectations for data security and risk management. Efficient implementation requires scoping your audit correctly and prioritizing the controls that matter most for your specific SOC 2 report.
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An Optimal Path to Meeting the SOC 2 Trust Services Criteria
The SOC 2 framework helps service organizations meet the diverse data security and compliance needs of their clients. Because the framework is flexible, it’s critical to execute a targeted and efficient SOC 2 assessment focused on the SOC 2 Trust Services Criteria.
Key steps include:
- Scoping your audit to determine which controls are required and how they should be assessed
- Implementing SOC 2 Common Criteria controls, mandatory for all audits
- Adding Additional Criteria controls, applied based on your organization’s specific needs
- Preparing for a SOC 2 Type 1 or Type 2 audit (or both), ensuring compliance and readiness
Partnering with an experienced SOC implementation team can streamline the process and ensure your organization meets the SOC 2 Trust Services Criteria efficiently.
Determining Your SOC 2 Trust Services Criteria Implementation and Audit Scope
The first step in SOC 2 compliance is determining whether your organization requires a SOC 2 audit and which type. The American Institute of Certified Public Accountants (AICPA) oversees three primary SOC frameworks:
- SOC 1: Focuses on financial reporting controls (for technical audiences)
- SOC 2: Focuses on Trust Services Criteria controls (for technical audiences)
- SOC 3: Focuses on Trust Services Criteria controls (for general audiences)
Scoping begins with choosing the right SOC framework. Financial services providers often require SOC 1, but many organizations also implement SOC 2 or SOC 3 depending on client expectations and regulatory requirements. Other service organizations typically pursue SOC 2 and/or SOC 3 audits.
Beyond framework selection, you must also determine the audit Type:
- Type 1: A faster audit requiring fewer resources, providing a snapshot of controls at a specific point in time.
- Type 2: A longer, more resource-intensive audit that evaluates controls over a period, offering stronger assurance to stakeholders.
Understanding your organization’s SOC 2 Trust Services Criteria requirements and audit type is essential for effective planning and efficient compliance.
Which SOC 2 Trust Services Criteria Controls Apply to Your Organization?
All SOC 2 and SOC 3 reports use the AICPA Trust Services Criteria (TSC), which cover Security, Availability, Processing Integrity, Confidentiality, and Privacy. The TSC is divided into nine sets of Common Criteria that apply to every assessment.
In addition, there are Additional Criteria organized under the TSC’s Trust Service Principles. These controls, except for Security, apply based on factors like the type of data your organization handles, environmental risks, and specific stakeholder requirements.
Installing only the controls your organization truly needs, while avoiding duplication with other regulatory or certification programs, is key to efficiently meeting the SOC 2 Trust Services Criteria and maintaining compliance.
Implementing SOC 2 Trust Services Criteria: Common Criteria Controls
The Common Criteria controls form the foundation of all SOC 2 assessments, making them the ideal place to start your compliance journey.
Most SOC 2 Trust Services Criteria are derived from the COSO framework. Within the Common Criteria (CC Series), the first five sets (CC1–CC5) align directly with COSO principles, while CC6–CC9 expand on COSO Principle #12, which addresses supplemental control policies.
In practice, this means you should prioritize CC1–CC5 first. Allocating the right resources to meet these foundational controls before moving to the remaining Common Criteria and Additional Criteria reduces backtracking and ensures a more efficient path to SOC 2 Trust Services Criteria compliance.
Baseline SOC 2 Trust Services Criteria: Common Criteria Series
The first five SOC 2 Common Criteria (CC1–CC5) form the foundation of the SOC 2 Trust Services Criteria, and they should be prioritized at the start of your implementation:
- Control Environment (CC1): Establishes governance principles and clear responsibilities across leadership and staff to safeguard all sensitive systems.
- Communication and Information (CC2): Ensures accurate reporting on system status and activities, along with effective communication throughout the organization.
- Risk Assessment (CC3): Provides the framework to identify threats, vulnerabilities, and risks, along with processes for detecting them in practice.
- Monitoring Activities (CC4): Tracks the functionality of internal controls and safeguards, ensuring they remain effective and updated.
- Control Activities (CC5): Ensures that all selected controls support the organization’s mission and goals while mitigating relevant risks.
These baseline controls are essential to efficiently meeting the SOC 2 Trust Services Criteria and provide a solid foundation for implementing the remaining Common and Additional Criteria.
Supplemental SOC 2 Trust Services Criteria: Common Criteria Series
The final four SOC 2 Common Criteria (CC6–CC9) build on the baseline controls and should be implemented after CC1–CC5 to fully meet the SOC 2 Trust Services Criteria:
- Logical and Physical Access Controls (CC6): Defines how access to hardware, software, and systems is granted, monitored, and controlled.
- System Operations (CC7): Ensures systems that handle sensitive data operate smoothly, with monitoring and threat mitigation in place.
- Change Management (CC8): Detects and secures changes to user data, ensuring all modifications are authorized and accounted for.
- Risk Mitigation (CC9): Implements strategies to neutralize potential and actualized risks, escalating issues as needed.
Prioritizing these supplemental controls after CC1–CC5 ensures an efficient and comprehensive path to SOC 2 Trust Services Criteria compliance
Implementing Additional SOC 2 Trust Services Criteria Controls
Beyond the Common Criteria, which cover Security, other Trust Services Categories have Additional Criteria controls. These controls may not be required for every SOC 2 assessment, but they help organizations meet the full SOC 2 Trust Services Criteria when relevant.
The Additional Criteria break down as follows:
- Availability (A Series): Ensures systems are available for internal and external users and meet all organizational objectives.
- Confidentiality (C Series): Protects sensitive data (excluding personal data) from unauthorized use according to organizational requirements.
- Processing Integrity (PI Series): Ensures that data processes are complete, accurate, timely, and authorized.
- Privacy (P Series): Protects personal data from unauthorized access or misuse in line with organizational objectives.
Depending on your organization and stakeholder requirements, some Additional Criteria may not need implementation. Consult with the stakeholder requesting the SOC 2 report or a SOC 2 compliance advisor before installing these controls.
Preparing for a SOC 2 Trust Services Criteria Type 1 or Type 2 Audit
Organizations pursuing SOC 2 Trust Services Criteria compliance can choose between a Type 1 or Type 2 audit. Although both audits assess the same control implementation, they differ significantly in scope, duration, and resource requirements.
Type 1 audits evaluate how your controls are designed at a specific point in time, providing a snapshot of compliance. In contrast, Type 2 audits monitor controls over a period, typically three months to a year, verifying not only proper implementation but also consistent operation and effectiveness throughout that period.
This difference in scope means preparing for turnaround times is critical. Type 1 reports can often be completed in a few weeks, while Type 2 reports require at least six months or more. Many organizations generate Type 1 reports for stakeholders while waiting for full Type 2 results, balancing efficiency with comprehensive compliance
Other SOC Compliance Considerations for SOC 2 Trust Services Criteria
While a SOC 2 Type 2 audit provides the highest level of security assurance in a single report, maximum efficiency may sometimes involve generating multiple SOC reports. Organizations often combine a SOC 2 report with a SOC 3 report, preparing both simultaneously to support B2B communications (SOC 2) and B2C marketing (SOC 3). SOC 3 does not carry a Type designation but generally requires a similar duration as a SOC 2 audit.
Beyond SOC 2 and SOC 3, other SOC frameworks target specific industry needs. Examples include SOC for Cybersecurity and SOC for Supply Chain, published by the AICPA.
Depending on your organization’s objectives, efficient SOC compliance may mean completing a single report or coordinating multiple reports in succession, all while maintaining alignment with the SOC 2 Trust Services Criteria.
Optimize Your SOC 2 Trust Services Criteria Reporting Process
Conducting a SOC 2 audit, whether Type 1 or Type 2, can feel overwhelming. Proper scoping, minimizing unnecessary controls, and preparing for your specific audit Type are key steps to make the process smoother and more efficient—especially when partnering with an experienced service provider.
At RSI Security, we’ve helped numerous organizations achieve and maintain SOC 2 Trust Services Criteria compliance. Our experts ensure your controls are implemented and assessed as efficiently as possible, protecting your stakeholders and strengthening your cybersecurity posture.
Ready to optimize your SOC 2 reporting process? Contact RSI Security today to streamline your compliance journey
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