SOC 2 — Requirements - SOC 2 is an auditing process that companies, SaaS providers and service providers go through in order to ensure proper data and privacy protections regarding sensitive data are in place. For an organization to achieve SOC 2 certification, a series of controls must be put in place and then validated, via an auditing process with an external auditing firm.
Auditors ensure compliance standards are met with one or more of the AICPA Trust Services (TSC). In order to achieve SOC 2 certification and receive a SOC 2 report, your team must ensure that all data and privacy protections regarding sensitive data are in place.
SOC 2 — Trust Services Criteria (TSC)
Your team must follow and implement the most up-to-date Trust Services Criteria (TSC) in order to obtain SOC 2 certification.
Trust Services Criteria consists of a set of related controls that an organization must implement across their IT infrastructure. They are as follows:
Security: network/application firewalls — two-factor authentication — intrusion detection
All data and computing systems must be protected against unauthorized access, inappropriate or unauthorized disclosure of information, and damage to systems that could compromise the processing integrity, availability, confidentiality, or privacy of data. Security criteria refer to your organization’s protection of:
- Information during its collection or creation, use, processing, transmission, and storage.
- Systems that use electronic information to process, transmit or transfer, and store information to enable your organization to meet its objectives. Controls over security prevent or detect the breakdown and circumvention of segregation of duties, system failure, incorrect processing, theft or other unauthorized removals of information or system resources, misuse of software, and improper access to or use of, alteration, destruction, or disclosure of information.
Availability: performance monitoring — disaster recovery — security incident handling
All information and computing systems are always ready and available for operation and use to meet the entity’s objectives. Availability refers to the accessibility of information used by your organization’s systems as well as the products or services provided to its customers.
- The availability objective does not, in itself, set a minimum acceptable performance level; however, It does address whether systems include controls to support accessibility for operation, monitoring, and maintenance.
- It also does not address system functionality (the specific functions a system performs) or usability (the ability of users to apply system functions to the performance of specific tasks or problems).
Processing Integrity: quality assurance — processing monitoring
All system processing is complete, accurate, valid, timely, and authorized to ensure that the entity meets its objectives. Processing integrity refers to your organization’s controls and procedures surrounding:
- Verifying the completeness, validity, accuracy, timeliness, and authorization of system processing.
- Determining whether systems achieve the aim or purpose for which they exist and whether they perform their intended functions in an unimpaired manner, free from error, delay, omission, and unauthorized or inadvertent manipulation.
- Because of the number of systems used by an entity, processing integrity is usually only addressed at the system or functional level of an entity.
Confidentiality: network/application firewalls — access controls — encryption
Any information designated as confidential remains secure to meet the entity’s objectives. Confidentiality refers to your organization’s controls and procedures including:
- Your organization’s ability to protect information designated as confidential from its collection/creation, through to its final disposition and removal.
- Confidentiality requirements may be contained in laws or regulations or in contracts and or agreements that contain commitments made to customers or others.
- Confidentiality differs from privacy criteria — privacy applies only to personal information, whereas confidentiality applies to various types of sensitive information.
Privacy: access control — two-factor authentication — encryption
Privacy criteria are used to examine your organization’s procedures and controls surrounding:
- Notification and communication of objectives: Notifications to remind subjects/users about objectives related to privacy.
- Choice and consent: Communication choices available regarding the collection, use, retention, disclosure, and disposal of personal information to data subjects.
- Collection: Collection of personal information to meet its objectives related to privacy.
- Use, retention, and disposal: Limits around the use, retention, and disposal of personal information to meet its objectives related to privacy.
- Access: Data subject access provided to their personal information for review and correction (including updates) to meet its objectives related to privacy.
- Disclosure and notification: How your organization discloses personal information (with the consent of the data subjects) to meet its objectives related to privacy. Ensuring that Notification of breaches and
incidents is provided to affected data subjects, regulators, and others to meet its objectives related to privacy. - Quality: How your organization collects and maintains accurate, up-to-date, complete, and relevant personal information to meet its objectives related to privacy.
- Monitoring and enforcement: How your organization monitors compliance to meet its objectives related to privacy, including procedures to address privacy-related inquiries, complaints, and disputes.
During a SOC 2 audit, an organization may be evaluated within the context of one or more TSC categories.
Remember: it is your responsibility to prepare for a SOC 2 audit — a reliable security program in place will streamline your audit, ensuring success.
Alignment with COSO Framework
COSO provides an organization with a generally accepted framework for internal controls within an organization. SOC 2 integrates the COSO framework including the five components of internal controls:
Note: the following components have been integrated into the latest SOC 2 Trust Services Criteria, providing a foundation for sound internal controls within an organization.
Control Environment
- Exercise integrity and ethical values
- Make a commitment to competence
- Use the board of directors and audit committee
- Facilitate management’s philosophy and operating style
- Create organizational structure
- Issue assignment of authority and responsibility
- Utilize human resources policies and procedures
Risk Assessment
- Create company-wide objectives
- Incorporate process-level objectives
- Perform risk identification and analysis
- Manage change
Control Activities
- Follow policies and procedures
- Improve security (application and network)
- Conduct application change management
- Plan business continuity/backups
- Perform outsourcing
Information and Communication
- Measure the quality of information
- Measure the effectiveness of communication
Monitoring
- Perform ongoing monitoring
- Conduct separate evaluations
- Report deficiencies
SOC 2 — Controls List
SOC 2 criteria and controls cover a wide number of security best practices across IT infrastructure and your organization including risk management, physical and logical access controls, and system access. Your team should establish a security program and consider working with a team like Dash in order to perform a readiness assessment and prepare for a SOC 2 audit.
The following categories of criteria are used to assess compliance with the SOC 2 Report Framework:
(CC1) Control Environment: addresses how an organization sets security roles, manages oversight and deals with security issues relating to employees, hiring, and overall management.
(CC2) Communication and Information: addresses how a team communicates IT and security requirements, responsibilities, and overall objectives across an organization.
(CC3) Risk Assessment: addresses how an organization manages risk analysis and identifies, addresses, and accepts risk across the organization.
(CC4) Monitoring Activities: addresses how an organization develops, monitors, and ensures that internal security controls are active and functioning.
(CC5) Control Activities: addresses how an organization establishes security controls, connects controls to policies and procedures and assigns duties.
(CC6) Logical and Physical Access Controls: address how an organization manages the physical security of its devices, as well as software and logical access restrictions to data.
(CC7) System Operations: Addresses how an organization handles system vulnerabilities, detects system operational issues, and responds to security incidents.
(CC8) Change Management: addresses how an organization handles development, testings, and the deployment of new systems and applications.
(A) Additional Criteria For Availability: defines additional standards for how an organization manages backups and overall system availability.
(C) Additional Criteria For Confidentiality: addresses how confidential information is identified and protected from destruction.
(PI) Additional Criteria For Processing Integrity: addresses how data is accurately processed and achieved.
(P) Additional Criteria For Privacy: addresses how personal information is collected, retained, and secured by an organization.
Want the full set of SOC 2 controls and requirements to be fully prepared? Download theour SOC 2 Control List Excel
SOC 2 Controls — Preparation & Implementation
All of this information has most likely left your head spinning. Upon first glance, implementing SOC 2 controls can seem like a daunting task; however, it doesn’t have to be this way. A SOC 2 readiness assessment can strengthen your team, better preparing you for what to expect during an audit to achieve SOC 2 certification.
Let us help you prepare: learn how Dash ComplyOps can help your team prepare and achieve SOC 2 certification in the cloud.