Service organizations that need to become SOC 2 compliant often struggle with scoping out their SOC 2 Report. Other issues include covering gaps in the control layout and allocating the resources needed for an audit. Working with a compliance partner helps solve for all of them.
Is your organization facing obstacles with SOC implementation? Schedule a consultation today!
SOC 2 Pain Points and How to Mitigate Them
The SOC 2 compliance framework is designed to be flexible; it empowers eligible organizations to install controls that meet their clients’ and other stakeholders’ stated expectations in a variety of ways. However, implementing and assessing to achieve compliance can still be challenging.
Many organizations’ pain points for SOC 2 compliance boil down to three categories:
- Uncertainty about whether you need a SOC audit (and what kind you need)
- Gaps and other issues with control deployment, relative to SOC 2 needs
- Difficulty allocating adequate resources for SOC 2 prep and assessment
Solving for these issues requires intentional design and resource allocation, which is significantly easier when assisted by a dedicated SOC 2 advisor organization.
Pain Point 1: Uncertainty in Audit Scope
The most fundamental obstacle to SOC 2 compliance is understanding which SOC framework applies and what controls need to be installed, for which purposes. SOC 2 shares much with SOC 3, as both measure controls laid out in the Trust Services Criteria (TSC) framework.
However, there are other considerations on this level as well. Some organizations may opt for an alternative SOC deployment, such as SOC for Cybersecurity or SOC for Supply Chain. And, if using the SOC 1 or SOC 2 security framework, you need to choose a Type of SOC Report.
Understanding scope allows for efficient implementation and audit preparation.
Determining Which SOC Reporting to Conduct
The three mainline System and Organization Controls (SOC) control frameworks overseen by the American Institute of Certified Public Accountants (AICPA) break down as follows:
- SOC 1 – These are reports on controls at service organizations related to user entities’ internal control over financial reporting (ICFR). They are intended for specialist readers and typically apply to financial service providers; they can be either Type 1 or Type 2.
- SOC 2 – These are reports on controls at service organizations related to security, availability, processing integrity, confidentiality, and privacy. They’re also intended for specialist readers and come in Type 1 or 2 but apply to a broader base of organizations.
- SOC 3 – These are reports on the same controls surveyed for SOC 2 but intended for more general audiences and public availability. They do not carry a Type designation.
Generally speaking, organizations conduct either a SOC 1 report or a SOC 2 and/or SOC 3 report. SOC 2 and SOC 3 apply to the same organizations but are intended for different audiences, whereas SOC 1 uses an entirely different framework for different purposes.
See below for resource allocation requirements relative to the two Types of SOC Reports.
Pain Point 2: Gaps in Control Deployment
Another pain point that bridges from scoping into implementation is installing and maintaining the controls necessary for SOC 2 compliance. Namely, organizations need to install controls from the TSC framework to meet the criteria. There are Common Criteria (CC) that apply to all SOC 2 audits and cover the principle of Security while also touching on other TSC principles.
Then, there are Additional Criteria pertaining to the other TSC principles. These may or may not be required for a given SOC 2 Report, as stakeholders requesting the report dictate whether these controls need to be assessed. If your organization is uncertain what scope is desired, it may be best to implement all controls. But if clients and prospects specify that their interest lies in just the CC, or the CC plus one or two Additional Criteria, you can optimize your installation.
Security and Overall Cyberdefense Deployment
The TSC Common Criteria cover all security needs for the framework and also touch upon certain elements of the other four principles. The nine CC series break down as follows:
- CC1 Series – Control Environment
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- CC1.1: Demonstrating a commitment to integrity and ethical values
- CC1.2: Maintaining board independence in oversight of internal controls
- CC1.3: Establishing logistics and responsibilities in pursuit of objectives
- CC1.4: Recruiting and retaining staff in alignment with objectives
- CC1.5: Holding individuals responsible for internal control objectives
- CC2 Series – Communication and Information
- CC2.1: Using relevant, quality information to support internal controls
- CC2.2: Communicating information relevant to internal control functions internally
- CC2.3: Disseminating information relevant to internal control functions externally
- CC3 Series – Risk Assessment
- CC3.1: Specifying objectives clearly to enable identification of relevant risks
- CC3.2: Identifying risks to objectives and methods for addressing them
- CC3.3: Considering the potential for fraud in objective risk identification
- CC3.4: Identifying and assessing changes that could impact internal controls
- CC4 Series – Monitoring Activities
- CC4.1: Performing assessments to ensure internal controls maintain functionality
- CC4.2: Communicating deficiencies to responsible parties in a timely manner
- CC5 Series – Control Activities
- CC5.1: Developing control activities that mitigate risks and support objectives
- CC5.2: Developing specialized technological controls to advance objectives
- CC5.3: Deploying controls through clear policies defining responsibilities
- CC6 Series – Logical and Physical Access Controls
- CC6.1: Implementing logical access infrastructure and architecture
- CC6.2: Authorizing individuals prior to issuing credentials and access
- CC6.3: Controlling access to data by principles such as least privilege
- CC6.4: Restricting physical access to facilities and information centers
- CC6.5: Discontinuing controls only after media is rendered unreadable
- CC6.6: Implementing access controls to account for outsider threats
- CC6.7: Restricting secure transmission of data to authorized parties
- CC6.8: Preventing, detecting, and acting upon unauthorized software
- CC7 Series – System Operations
- CC7.1: Identifying changes resulting in new vulnerabilities or susceptibility
- CC7.2: Monitoring for and analyzing anomalies that could disrupt objectives
- CC7.3: Determining if events impact objectives and if/how to address them
- CC7.4: Responding to identified security incidents in a programmatic manner
- CC7.5: Identifying, developing, and implementing incident recovery protocols
- CC8 Series – Change Management
- CC8.1: Controlling and implementing changes to infrastructure to meet objectives
- CC9 Series – Risk Mitigation
- CC9.1: Minimizing the impact of risks that threaten business interruption
Every SOC 2 audit requires implementing all of these controls at a minimum.
Additional Criteria Control Deployment
Beyond the baseline Common Criteria, the SOC 2 control framework also includes Additional Criteria related to the other TSC principles besides security. Some SOC 2 audits assess all available controls, whereas others pertain only to the CC or a select set of Additional Criteria.
The first set of Additional Criteria relates to the TSC principle of Availability:
- A Series – Additional Criteria for Availability
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- A1.1: Maintaining and monitoring system capacity to enable adjustments
- A1.2: Maintaining environmental protections, recovery infrastructure, etc.
- A1.3: Testing recovery plans and procedures to meet defined objectives
The next couple Criteria relate to Confidentiality, or protection of non-personal information:
- C Series – Additional Criteria for Confidentiality
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- C1.1: Identifying and maintaining confidential information per defined objectives
- C1.2: Disposing of confidential information in a timely manner per objectives
Next, there are Processing Integrity Criteria, to ensure the completeness of data processes:
- PI Series – Additional Criteria for Processing Integrity
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- PI1.1: Obtaining, using, and communicating information related to processing
- PI1.2: Controlling all system inputs to ensure completeness and accuracy
- PI1.3: Implementing procedures to ensure completeness and accuracy
- PI1.4: Controlling all system outputs to ensure completeness and accuracy
- PI1.5: Implementing policies to store inputs, processes, and outputs securely
Finally, there are Privacy Criteria, which ensure protection of personal information:
- P1 Series – Privacy Criteria Related to Notice and Communications
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- P1.1: Providing updated information about privacy practices to data subjects
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- P2 Series – Privacy Criteria Related to Choice and Consent
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- P2.1: Empowering and obtaining consent regarding personal data processing
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- P3 Series – Privacy Criteria Related to Collection of Personal Data
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- P3.1: Ensuring personal data collection is aligned with defined objectives
- P3.2: Communicating and requiring consent for personal data processing
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- P4 Series – Privacy Criteria Related to Use, Retention, and Disposal
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- P4.1: Limiting the use of personal information to defined purposes
- P4.2: Retaining personal information according to defined objectives
- P4.3: Securely disposing of personal information per defined objectives
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- P5 Series – Privacy Criteria Related to Access to Personal Information
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- P5.1: Granting data subjects the ability to access their personal data
- P5.2: Making adjustments and corrections requested by data subjects
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- P6 Series – Privacy Criteria Related to Disclosure and Notification
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- P6.1: Disclosing information to third parties only with consent from data subjects
- P6.2: Retaining accurate updated records of personal information disclosure
- P6.3: Retaining records of detected or reported unauthorized data disclosures
- P6.4: Obtaining privacy commitments from third parties regarding personal data
- P6.5: Ensuring third parties inform impacted parties about data disclosure
- P6.6: Providing breach notifications to impacted subjects and authorities
- P6.7: Providing data subjects with information about data processing
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- P7 Series – Privacy Criteria Related to Quality Assurance
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- P7.1: Maintaining accurate, updated personal data per defined objectives
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- P8 Series – Privacy Criteria Related to Monitoring and Enforcement
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- P8.1: Monitoring for and resolving disputes related to personal information
Depending on the context of your SOC 2 assessment, some or all of these criteria might be required. To avoid overlap or unnecessary work, be sure to install only the controls you need.
Pain Point 3: Time and Resource Constraints
The final major hurdle to SOC 2 compliance is allocating the appropriate time and resources for your implementation and audit. For the audit specifically, the SOC 2 framework empowers two Types, which correspond to resource costs and security assurance commensurate with them.
Type 1 audits for both SOC 1 and SOC 2 produce Reports on the design of controls relative to the criteria being assessed against. They are snapshots of a control system at a given point in time and require relatively few resources to produce. A SOC 2 Type 1 audit, for example, can take as little as a few weeks and typically no more than six months, maximum, to complete.
Type 2 audits, on the other hand, are far more resource-intensive. They are longitudinal studies of control efficacy over time, ensuring that systems are capable of maintaining security over a significant duration. They often take at least six months to complete and can take well over a year in many cases. But the results are unparalleled security assurance for all stakeholders.
Best Governance Practices for SOC 2 Audit Prep
Audit preparation, especially for Type 2 Reporting, requires sound and efficient cybersecurity governance. That starts at the top, with clear communication of responsibilities from leaders such as Chief Information Security Officers (CISOs). For many growing organizations, there may not be a CISO in place. The expertise required makes talent hard to recruit and retain.
Enter the Virtual CISO (vCISO), an alternative that provides all of the functionality that a traditional, C-suite executive can at a fraction of the cost. With a vCISO partner, you can streamline compliance preparation for SOC 2 and other upcoming audits. And the external perspective can help to identify issues an internal stakeholder might be positioned to miss.
A vCISO or other managed security service provider (MSSP) can help you rethink your security.
Solve for Your SOC 2 Struggles Today
Ultimately, SOC 2 compliance is challenging because of the sheer scale and complexity of the implementation and assessment processes. You need to scope these out accurately, install all the controls you need, and then allocate appropriate resources for a Type 1 or Type 2 audit.
RSI Security has helped countless organizations prepare for and achieve SOC 2 compliance, including both Type 1 and Type 2 reporting. We know that the right way is the only way to keep your data and its subjects safe. We believe that discipline now unlocks greater freedom down the road, like the ability to expand within your industry or across industries and locations.
To learn more about SOC 2 framework compliance, contact RSI Security today!
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