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How to Overcome Common Challenges of the SOC 2 Framework

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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:

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:

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: 

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:

The next couple Criteria relate to Confidentiality, or protection of non-personal information:

Next, there are Processing Integrity Criteria, to ensure the completeness of data processes:

Finally, there are Privacy Criteria, which ensure protection of 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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