Read this handy guide to SOC 2 compliance to learn what SOC 2 is, when you need it, and how to become compliant.
SOC 2 is an information security standard, created by the American Institute of Chartered Public Accountants (AICPA) to provide assurance of an organisation’s management of data.
Despite being a primarily US-centric standard, demand for SOC 2 compliance is increasing all the time in the rest of the world, including here in the UK. At its core, SOC 2 is a compliance standard designed to ensure strong levels of information security inside a business. In this way, SOC 2 shares a lot of similarities in its aims and objectives with ISO 27001 , so completing one gives a head start on the other.
As I mentioned previously, there are five principle areas that comprise SOC 2 and together they’re called the Trust Services Criteria (TSCs). Of the five SOC 2 TSCs, only one is mandatory for compliance. Whether you need to comply with the other four depends on the underlying factors driving your SOC 2 compliance.
Security is the only mandatory principle in the TSCs, and as such it’s often referred to as the ‘common criteria’ (CC). There are 9 points of focus within the security TSC:
CC1 Control Environment
CC2 Communication and Information
CC3 Risk Assessment
CC4 Monitoring Activities
CC5 Control Activities
CC6 Logical and Physical Access Controls
CC7 System Operations
CC8 Change Management
CC9 Risk Mitigation
Availability means that systems and data must remain accessible to users. Organisations should explore performance monitoring to prevent downtime affecting business-as-usual, as well as have a robust disaster recovery plan in place to keep your business online.
The goal of this TSC to make sure your organisation’s system and information processing remains intact. Factors to consider here include validity, accuracy and timeliness of processes to support your operations.
Confidentiality means that access to data should be restricted, controlled and recorded. If an incident were to take place, you would have a full audit report to prove you have maintained data confidentiality in line with the SOC 2 compliance requirements.
Privacy should live and breathe throughout your business, for example, guiding how you collect, store, process, and dispose of data. This TSC is nearly as big as the Security TSC, so it can add significant work to SOC 2 compliance.
The types of SOC 2 compliance vary more than their name might suggest, with Type II being much more in-depth and, as a result, more valuable. That’s why it’s the most popular of the two types of SOC 2 compliance.
SOC 2 Type I is a point-in-time assessment of your organisation against the relevant TSCs. As a one-off exercise, it’s cheaper and more accessible than the more in-depth Type II, but that also means it doesn’t give as thorough assurance
SOC 2 Type II is a measurement of your organisation’s adherence to the TSCs over a period of time – usually a few months. As an assessment over time, it’s naturally a more involved process. Whilst this makes SOC 2 Type II compliance more expensive, it also makes it more desirable: it’s a robust assurance that you’re meeting the required standards.
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Find out how easy SOC 2 can beSome people are surprised when I tell them that SOC 2 compliance is not a formal legal requirement, meaning the driver to reach compliance is commercial, not legal. Not every service provider will have completed SOC 2 meaning that, in competitive situations, SOC 2 compliance provides you with a distinct advantage. SOC 2 is also often mandated in contracts, making SOC 2 compliance a direct business enabler.
Some people are surprised when I tell them that SOC 2 compliance is not a formal legal requirement, meaning the driver to reach compliance is commercial, not legal.
Unlike contemporary compliance standards, such as ISO 27001 , successfully meeting SOC 2 compliance does not come with a certificate! There’s no such thing as SOC 2 certification. Instead of a certificate, compliance is attested by a report that can only be provided by an AICPA-registered auditor. These reports include a detailed description of your systems, the results of the tests, and a management assertion on how well you meet the standard.
Contrary to what the name suggests, SOC 2 is not an update of SOC 1. They are two different compliance standards, with different goals, and one or both could be right for your organisation.
SOC 2 is the more common, and robust, of the two types. If you only handle non-financial data, choose SOC 2. But if you do handle financial data, or you need Sarbanes-Oxley (SOX) compliance to become a publicly traded company, a SOC 1 audit is also needed.
SOC 2 Type I is a point-in-time assessment of your organisation against the relevant TSCs. As a one-off exercise, it’s cheaper and more accessible than the more in-depth Type II, but that also means it doesn’t give as thorough assurance
SOC 1 focuses specifically on internal controls over financial reporting to help users understand the impact controls have on the organisation’s financial statements.
Looking for a head start? One of the questions I get asked the most by people wondering ‘what is SOC 2 compliance’, is the broad-steps process. So, I’ve got a quick 8-point checklist covering what businesses need to do to work towards SOC 2 compliance.
Have a clear understanding of the SOC 2 framework’s aims and requirements. Fully understanding the details of SOC 2 is absolutely essential to successfully achieving SOC 2 compliance.
Assess your security posture Fully review all aspects of your security posture. This includes identifying the data that you collect and process, the risks to that data, and mitigating controls.
Implement the required technical, procedural and administrative controls as required. I’ve found that this is where accurate scoping and understanding the framework really help.
Make sure SOC 2 is included in your employee security awareness training. Educate employees about the importance of security and the steps that they must take to protect data.
Make sure that your incident response plan is up-to-date and that you have the resources in place to respond to various types of security incidents.
Review your security posture on a regular, ongoing basis. This includes reviewing your controls, conducting security assessments, and responding to security incidents.
For SOC 2 you must write things down. I hope that’s not a surprise. Document all the controls you have implemented, as well as the evidence that they are operating effectively.
Finally, a SOC 2 audit from an external AICPA auditor will assess your controls and issue a Type I or Type II report on your SOC 2 compliance status. Congratulations!
As with a lot of things in the information security field, the process is always far easier when you do the right groundwork. With that in mind, here are 4 top tips for SOC 2 compliance from my experience
SOC 2 compliance can be a significant undertaking, so it’s a big help to get buy-in from senior management. I see that, when the top levels of an organisation are on-board with a project, it’s much easier to get the time and resources needed to see the project through.
Once you have senior management buy-in, it’s a great idea to put together a compliance team to oversee the whole process. This team should include representatives from all departments involved in the SOC 2 compliance process, such as IT, security, and risk management.
Using the right compliance management tool can help you to automate many of the tasks involved in SOC 2 compliance, such as risk assessments, control testing, and documentation. Bulletproof uses an automated compliance platform to help make SOC 2 as easy as possible for both me and the customer!
If SOC 2 compliance feels like an uphill struggle, don’t worry. There are always people like me out there who’ve done this before and know how to take you through this process. A trusted SOC 2 consultant can help your business through it all: scoping, implementing controls, and audit readiness. They can also help you get things like SOC 2 penetration tests, and see where efficiencies can be made with other compliance frameworks.
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