Key Takeaways
1. Password requirements and management are primarily addressed under the Security criterion of the Trust Services Criteria.
2. Passwords must meet security standards, which include a minimum of twelve (12) characters, the use of complex characters, regular changes every 60 to 90 days, and a prohibition on reuse for at least six months.
3. Adhering to SOC 2 password requirements will enhance long-term confidence in your data security. Achieve SOC 2 compliance with IS Partners.
What Are SOC 2 Password Requirements?
The SOC 2 Framework does not specifically provide a list of standards regarding password requirements but mandates that organizations implement effective controls to safeguard data, including password management policies. Along with this mandate are commonly applied best practices for managing passwords.
SOC 2 password requirement guidelines and best practices include the following:
- Passwords must be of a minimum length, typically at least 12-16 characters.
- Passwords must meet specific criteria for complexity, often including a mix of upper and lower case letters, numbers, and special characters.
- Passwords must be changed regularly (the frequency is debated but usually between 60-90 days).
- New unique passwords must be significantly different from previous ones.
- Account must be locked after multiple (3-4 times) failed attempts and;
- Multi-factor authentication (MFA) adds an extra layer of security by requiring additional verification steps beyond just the password.
Passwords are the first defense against unauthorized access to personal or sensitive information. According to a 2020 Verizon Data Breach Investigations Report, 81% of hacking-related breaches leveraged stolen or weak passwords. This statistic shows the importance of implementing robust password policies.
Detailing the SOC 2 Password Requirements
SOC 2 password requirements are found under CC6 of the COSO Principle 12 Supplemental Criteria, which focuses on logical and physical access controls. CC6 includes eight sub-categories aimed at managing access control risks, three of which specifically address password requirements.
Below are the three subcategories of the common criteria:
Logical Access Security (CC6.1)
This subcategory focuses on the implementation of robust logical access security measures. It requires that an organization implement logical access security software, infrastructure, and architectures over protected information assets to protect them from security events and meet security objectives.
It includes requirements for:
Password Complexity
A complex password is a random combination of characters that is difficult to guess and crack. It should include a combination of
- uppercase letters and lowercase letters,
- numbers,
- special characters and be at least 8 characters long.
Using different characters makes passwords very difficult to guess or predict. The longer and more complex a password is, the better.
Short passwords, such as birthdays or something as simple as ‘name123, ‘ can easily be guessed by crime actors. These patterns are often included in password dictionaries used by attackers in dictionary attacks. An example of a complex, strong password is Qs9#pL2@xR4$mN. It is 13 characters long and does not include any personal information.
Password Length
The industry standard recommendation for password length is a minimum of 12-16 characters. Each additional character in a password exponentially increases a password’s resistance to brute-force attacks.
Regular Password Change and Password Rotation
The password requirements for SOC 2 compliance also demand that organizations have a documented password policy that addresses password complexity, expiration, and reuse. Historically, 60-90 days was a common recommendation for password changes; however, current cybersecurity thinking has evolved on this topic.
The National Institute of Standards and Technology (NIST) now recommends against mandatory periodic password changes unless there’s evidence of compromise. Instead of frequent password changes, current recommendations focus on using longer, more complex passwords or passphrases, implementing multi-factor authentication (MFA), monitoring for compromised credentials, and encouraging password changes only when there’s suspicion of compromise.
The drawback of frequent password changes is that they can lead to “password fatigue,” potentially causing users to choose weaker passwords or resort to writing them down.
Account Lockout
Account lockout mechanisms are important security measures designed to stop brute-force attacks. Brute force attacks involve repeatedly attempting to access a user account by systematically trying numerous password combinations.
A common practice is to temporarily disable user access to an account after a specific number of unsuccessful login attempts, usually three or more.
This approach is based on the understanding that malicious actors often employ automated tools or scripts capable of testing thousands of password combinations within minutes.
Authentication and Authorization (CC6.2)
This sub-category focuses on ensuring that users are authenticated and authorized before they can access sensitive data or systems. The subcategory requires that before issuing system credentials and granting access, the organization registers and authorizes new internal and external users. For
System credentials are removed for users whose access is managed by the organization when their access is no longer authorized.
It includes using multi-factor authentication (MFA) and passwords to provide an extra layer of security. It also addresses the management of user identities and the assignment of access privileges based on the principle of least privilege.
MFA is a security mechanism that requires users to provide two or more verification factors to gain access to a resource. The factors may be
- Something You Know: Passwords, PINs, security questions
- Something You Have: Mobile phones, hardware tokens, smart cards
- Something You Are: Biometrics (fingerprints, facial recognition)
While SOC 2 doesn’t explicitly mandate the use of MFA, otherwise called two-factor authentication, it is strongly recommended and often expected by auditors as a best practice for meeting the security principle. It addresses weaknesses associated with password-only authentication.
Password Management Practices (CC6.3)
This subcategory outlines best practices for managing passwords, including:
- Implementing strong hashing algorithms for password storage
- Using password managers to generate and store complex passwords
- Applying encryption for password transmission and storage
- Enforcing password complexity and length requirements
- Implementing multi-factor authentication (MFA)
It also covers the need for regular monitoring and testing of password policies so they can be effective and up to date.
CC6.3 stresses the importance of documenting password management procedures and training users on best practices for creating and maintaining strong passwords.
Implementing the necessary controls to meet these password guidelines is a step towards becoming SOC 2 compliant. To assist you in this journey, IS Partners offers comprehensive SOC 2 audit services. Our expert auditors will prepare you for SOC 2 Type 1 and Type 2 audits and help you set up the appropriate controls to ensure long-term security assurance.
Best Practices to Comply With SOC 2 Password Requirements
Fulfilling the demands of the SOC 2 password requirements involves implementing a range of security measures to ensure that passwords are robust and protected. Here is how you can meet all SOC 2 password requirements and stay compliant with SOC 2:
- User Training. Educating users about the importance of creating and maintaining strong passwords is vital. Training sessions should cover best practices, such as using a mix of uppercase and lowercase letters, numbers, and special characters.
- Password Management. This can be achieved by using password management tools and hashing algorithms, which convert passwords into a fixed-length string of characters that is not easily reversible. Hashing ensures that even if someone gains access to the stored data, they cannot retrieve the actual passwords.
- Regular Security Audits and Continuous Monitoring. SOC 2 compliance requires ongoing monitoring and testing of password policies and controls. This involves regularly reviewing password strength, usage patterns, and access logs to detect anomalies or potential security breaches.
CPA auditors at IS Partners can help conduct regular audits and achieve compliance with SOC 2 standards and other regulatory frameworks.
- Documentation. Proper documentation of all password-related policies and procedures is essential for SOC 2 compliance. This includes detailing how secure passwords are created, stored, and managed. The processes for user training must also be properly documented.
Comprehensive documentation provides a clear framework for auditors and demonstrates your organization’s commitment to maintaining good security practices.
Optimize SOC 2 Access Control with IS Partners
SOC 2 compliance strongly emphasizes data and system security, with passwords serving as a critical first line of defense. However, if not properly managed, passwords can also be a significant vulnerability.
Complying with SOC 2 password security requirements will enhance the long-term security of your data, especially when guided by a SOC 2 compliance auditor. IS Partners offers specialized assistance in optimizing these standards.
Our experts work collaboratively with your team to implement robust password security controls that align with SOC 2 requirements. With over 20 years of experience in the compliance industry, our experts have mastered the optimal way of maintaining compliance consistently.
We streamline the compliance process by offering comprehensive SOC 2 services under one roof, saving you precious time and resources. Speak with our auditors and learn how we can assist with your SOC 2 compliance needs.
Schedule a consultation with our experts today.
