Expert Advice on How to Get SOC 2 Compliance

How to Become SOC 2 Compliant For Service Organizations

To achieve SOC 2 compliance, you must prepare for the SOC 2 (System and Organization Controls 2) audit and attestation process. This involves establishing robust security controls and engaging with a reputable CPA firm (Certified Public Accountants) to validate the effectiveness of these standards. 

Companies should develop a good security program roadmap and collaborate closely with assessors to address and resolve any security concerns, such as data breaches. Comprehensive preparation is key to identifying critical vulnerabilities in their systems, which can be addressed through a readiness assessment. 

Below is a clear SOC 2 compliance checklist you can use to guide your team.

Step 1: Identify Your Objectives and Purpose of Pursuing SOC 2

For many companies, the main purpose of SOC 2 is to ensure that third-party service providers securely store and process client’s personal information. It can also build a strong sense of reliability and boost a brand’s reputation in the market. 

To achieve these benefits, clarifying your reasons for getting SOC reports is essential. 

Use the following questions to clearly identify your objectives and the main purpose of pursuing a SOC 2 audit.

• What primary objectives do you aim to achieve by pursuing SOC 2 compliance?
• How will SOC 2 compliance benefit your organization in terms of security and build trust?
• What specific business goals do you hope to support through obtaining SOC 2 attestation?
• Are there any particular customer or market demands driving your pursuit of SOC 2 compliance?
• How will SOC 2 security compliance align with your overall risk management strategy?
• What are the potential impacts on your operations if you do not achieve SOC 2 compliance?
• How does SOC 2 compliance integrate with your existing compliance and regulatory requirements?

Step 2: Determine the Type of SOC 2 Report

The two main types of SOC 2 compliance are Type 1 and Type 2.  SOC 2 Type 1 report is ideal for organizations that must demonstrate that their systems and controls are properly designed and in place at a specific time. It is preferred when your business partners want an initial confirmation of security measures without needing a historical performance review.

On the other hand, the SOC 2 Type 2 audit is for organizations that need to prove that their controls are not only in place but also effective over an extended period of time (usually 12 months). The type II report is preferred when clients or stakeholders require evidence of consistent operational effectiveness and security over time.

Step 3: Define the Scope and Select the Appropriate Trust Service Criteria

The scope of SOC 2 includes the systems and cloud services that customers rely on. It should cover an organization’s services, systems, policies, intellectual property, processes, and people. This scope is evaluated against the five trust principles: security, availability, processing integrity, confidentiality, and privacy.

Next, you must decide which Trust Services Criteria (TSC) will be assessed. These security criteria guide the audit’s focus, determining which controls and processes will be assessed. You can choose one or more categories while the Security criterion is mandatory. 

Teams should collaborate with an assessor to determine which criteria are most relevant and should be included in your audit readiness step.

• Security: Core SOC 2 requirement, covering IT security and governance.
• Availability: Ensures uptime through IT capacity, performance, and recovery.
• Processing Integrity: Ensures accurate data handling by IT and product teams.
• Confidentiality: Limits access to sensitive data, managed by IT.
• Privacy: Protects personal data, involving IT, support, and legal.

Step 4: Build a Strong Compliance Team

The next step in SOC 2 preparation is selecting the right leaders. While IT and information security teams are vital, forming your core SOC 2 team should involve HR, legal, and other key business units. Here are some of the roles:

• Executive Sponsor. A strategic leader who links SOC 2 goals to future revenue and is skilled in risk management.
• Project Manager. Drives SOC 2 initiatives across departments with precision, excelling in task management.
• Primary Author. Senior expert in technical writing and business operations, streamlining SOC 2 compliance standards.
• Legal Team. Refines policies and manages contracts critical for SOC 2 alignment, providing ongoing support.
• IT/Security. Implements robust technical solutions, enhancing security and compliance readiness.
• External Consultant (Optional). Offers expertise in navigating SOC 2 complexities and integrating compliance requirements.
• Other Employees. Essential team members adapting to new policies, ensuring smooth SOC 2 adoption.

Step 5: Collect All Relevant Documents to the Audit

Preparing for a SOC 2 audit involves providing external auditors with documentation demonstrating the security of your policies, processes, and systems. The specific documents required depend on your audit’s scope. Here are examples of documents you may need:

• Controls matrix: A spreadsheet listing all controls relevant to the audit.
• Asset inventories
• Change management information
• Equipment maintenance records
• System backup logs
• Code of conduct and ethics policies
• Business continuity and incident response plans
• Administrative security policies
• Technical security control documentation
• Third-party and vendor contracts
• Risk assessment and audit documentation

Step 6: Conduct a Risk Assessment

A key part of SOC 2 compliance is conducting a thorough risk assessment or SOC 2 readiness assessment. The process involves identifying potential risks to your business, evaluating their likelihood and impact, and implementing appropriate safeguards (SOC 2 controls). 

Joe Ciancimino, Director of SOC Practice at I.S. Partners, was asked for recommendations on improving oversight and monitoring of third-party vendors to mitigate risks and maintain SOC 2 compliance. He responded,

At I.S. Partners, we highlight its importance because it uncovers threats that could affect your essential systems. Mastering risk analysis requires specialized skills to assess, evaluate, and mitigate risks effectively; our experts are well-versed in this.

Step 7: Conduct a Gap Analysis 

Gap analysis ensures all critical controls are documented and in place by comparing your system against chosen criteria. It helps detect issues early, allowing corrections before audits, so it allocates enough time for remediation.

Your team identifies existing SOC 2 controls, identifies gaps, and assigns responsibility for remediation. Typical issues found include the following:

• A lack of core customer data protection policies 
• Inconsistent background checks
• Inadequate employment agreements on cybersecurity
• Outdated password policies.

Step 8: Perform a Readiness Assessment

Some service organizations perform their readiness assessment internally as a SOC 2 self-assessment. Whether conducted internally or with the help of a consultant, a readiness assessment typically follows these steps:

• Map your existing controls to the SOC 2 Trust Services Criteria relevant to your organization. This involves identifying which controls and documentation are already in place. 
• Next, identify any gaps that may exist. This phase may reveal missing controls or highlight the need to redesign processes, implement employee training programs, or gather additional evidence for existing controls.
• Develop a remediation plan that outlines specific timelines and deliverables for addressing identified gaps. Assign responsibility to an individual for monitoring progress and ensuring that remediation efforts stay on track.

Step 9: Conduct the Remediation Process

Use the results of your readiness assessments to drive ongoing improvement in your organization’s compliance efforts. Regularly assess and enhance internal controls, policies, and procedures to align with emerging risks and industry standards.

After analyzing assessment findings, devise remediation plans to resolve identified gaps and deficiencies. Each plan should detail specific actions, assign responsibilities, and set target completion dates. 

This phase focuses on making necessary updates and enhancements to address these gaps, which may involve adjusting workflows, refining policies, or implementing stage-appropriate controls.

Step 10: Establish a Continuous Monitoring Program

You need continuous monitoring to maintain the SOC 2 Type 2 compliance program over a specific period. This ensures you can quickly address issues and avoid gaps, such as letting your onboarding program go unmanaged for weeks.

An effective monitoring program involves regularly logging sensitive information and analyzing patterns and potential anomalies. Using software tools and vulnerability scanners can help keep everything on track and ensure ongoing compliance.

SOC 2 Compliance Requirements

SOC 2 compliance is a framework that ensures service organizations manage customer data based on five trust service criteria. SOC 2 requirements consist of tasks that involve adherence to these criteria. 

1. Security. Measures must be put in place to protect sensitive information against unauthorized access. This includes physical and logical security controls, such as firewalls, intrusion detection systems, encryption, and access controls.
2. Availability. Systems should be operational and accessible as agreed upon in service-level agreements (SLAs). This involves implementing redundancy, backup procedures, and disaster recovery plans to ensure services are available when needed.
3. Processing Integrity. Data processing must be complete, valid, accurate, timely, and authorized. Organizations need to establish quality assurance processes, error-handling mechanisms, and integrity checks to ensure the reliability of their systems.
4. Confidentiality. Sensitive information must be protected from unauthorized access. This requires implementing encryption, access controls, and secure data handling practices to ensure that confidential information is only accessible to authorized individuals.
5. Privacy. Personal information must be collected, used, retained, disclosed, and disposed of by the organization’s privacy policy and relevant regulations. This involves data minimization, consent management, and secure data disposal practices.

In addition to the requirements from the chosen focus, SOC 2 also features common criteria that must be met. Key aspects evaluated under the common criteria include:

1. Logical and physical access controls to prevent unauthorized system access
2. System monitoring for malicious or unrecognized activity
3. Change management procedures for system configuration changes
4. Risk assessments to identify and mitigate security risks
5. Incident response plans for security incidents
6. Vendor management programs to assess third-party risks

Ciancimino highlighted key strategies and requirements to maintain consistent SOC 2 compliance, 

Achieving SOC 2 compliance demonstrates a commitment to data security and privacy and builds trust with clients and partners, ensuring that the organization meets the highest standards for managing customer data.

How to Maintain SOC 2 Compliance Status?

The concept of SOC 2 is not a one-time thing. The framework must be consistently monitored and verified to reap the benefits of compliance. Your SOC compliance team is responsible for ensuring that your system is protected from unauthorized access and that controls are still working.

To facilitate the SOC 2 compliance maintenance process, implement these steps and culture into the process.

1. Treat compliance as an ongoing process. Embrace the idea that policies and procedures will evolve over time. Update documentation when changes are made and communicate updates to relevant parties.
2. Perform periodic requirements like policy reviews and vendor assessments. Use an automated scheduler or task management app to set reminders.
3. Continuously monitor security controls to ensure they remain effective. Set up anomaly detection and real-time alerts to identify potential incidents or compliance gaps. Documentation can speed up the reassessment for your next SOC 2 audit.
4. Maintain detailed audit trails and logs of system activity, data access, and configuration changes. This provides crucial evidence during audits.
5. Communicate regularly with staff and management about the operating effectiveness of your SOC 2 compliance program. Share metrics on compliance tickets, policy updates, etc., to keep compliance at the forefront of your mind.
6. Perform internal audits and mock assessments throughout the year to identify and remediate compliance gaps before the official audit.
7. Engage your auditor for a Type 2 audit covering a 6-12 month period before your current SOC 2 report becomes stale.

The key is to ingrain SOC 2 compliance practices into daily operations, leveraging automation where possible to maintain your compliance posture between formal audits efficiently. Treating compliance as a continuous process rather than a point-in-time exercise is crucial for staying audit-ready.

Accelerate Your SOC 2 Compliance With I.S. Partners

Achieving SOC 2 compliance is critical for building trust with clients and safeguarding sensitive data. By adhering to the highest standards for security, availability, processing integrity, confidentiality, and privacy, your organization demonstrates a strong commitment to protecting information and meeting industry demands.

Ready to strengthen your compliance posture? Contact I.S. Partners today to schedule a consultation and accelerate your SOC 2 compliance process.

About The Author

Jena Andrews

Jena is a senior auditor and security consultant since 2021. She is specialized in compliance management, cybersecurity, IT security, and risk management. Jena is a certified information systems auditor (CISA) and project manager.

With a decade-long history in Project Management, Jena has focused the past five years on Compliance, IT and Operations auditing, Information Security, and Cybersecurity. She has conducted a plethora of compliance audits and security assessments in accordance with standards including SOC 1, SOC 2, HIPAA, PCI DSS, ISO 27001, and NIST 800-53, 800-171.

Jena is a proud B.S. graduate in Criminal Justice from West Chester University and holds esteemed CISA, PMP, and CCP certifications, further highlighting her expertise and commitment to professionalism.