Understanding the SOC 2 controls list and the role it plays in a SOC 2 audit
At first glance, becoming SOC 2 compliant can feel like navigating a complex maze. Sure, you’re aware of the necessity of ensuring that your organization protects customers’ data security, but in an ever-changing digital world, the security standards that organizations should adhere to are strict and non-negotiable. Clients are less likely to trust an organization that does not comply with a leading security standard like SOC 2.
In this article, we’re looking at what SOC 2 controls are, and the role they play in becoming SOC 2 compliant. But first, let’s do a quick refresher on some of the key terms that are used throughout the blog.
SOC 2 is a reporting framework that can be considered the security blueprint for service organizations. Developed by the AICPA, especially for service organizations, this reporting framework allows SaaS companies to verify that they meet what is considered peak-quality data security standards.
SOC 2 controls
Your controls are the intentional tools and processes you’ve implemented into your organization to fulfill a specific security purpose. Let’s say you’re feeling somewhat tired and you’ve decided that you need to do something about it. The purpose is to re-energize yourself, the control may be to grab a cup of coffee. Alternatively, a control may be taking your daily vitamins, grabbing an energy drink, or perhaps catching up on some sleep. The same principle applies to SOC 2 controls. Controls differ within each overarching TSC requirement, and that’s ok. They are not tested by their ability to meet their objectives and whether or not they are implemented appropriately. That’s what your SOC 2 audit will reveal.
In other words, SOC 2 is the overall security framework. SOC 2 controls are the measures, practices and processes taken to meet the organization’s SOC 2 objectives.
AICPA’s Trust Services Criteria
SOC 2 is guided by a list of five TSCs, Security, Availability, Processing Integrity, Confidentiality, and Privacy. Determining which TSC needs to be covered is a crucial part of preparing for your SOC 2 audit. However, the beauty of SOC 2 lies in its flexibility. Out of the five TSCs, it is only compulsory that your organization complies with the first criterion – Security. As for the remaining TSCs, it’s left to the discretion of each individual organization as to whether or not SOC 2 compliance within that criteria would benefit and is relevant to their organization. However, be cautious of risking a potential competitive advantage due to the scope of your SOC 2 implementation being too narrow. For example, if your clients are likely to value reliable, always-on service, then it may be strategically shortsighted not to implement controls to meet the Availability criterion.
The purpose of SOC 2 controls
In essence, a SOC 2 control is the system or process that your organization implements in order to meet its SOC 2 compliance and information security objectives. The focus is on whether or not your organization fulfills predetermined objectives of control design and effectiveness within your selected TSC criteria. That being said, the natural first step is to know what these requirements are and to subsequently start implementing controls that not only align with these said requirements but that work best for your specific organization.
The Trusted Service Criteria (TSC) requirements
There are five Trusted Service Criteria (TSC) that make up the backbone of SOC 2. To become SOC 2 compliant, your organization needs to meet these requirements. Note, that you do not have to meet all five criteria. Rather, each organization determines which TSCs are relevant and desirable, and then designs SOC 2 controls to achieve those goals. However, the first criterion, Security, is obligatory in all cases.
Within each TSC, there are specific multiple controls that can be tested.
The five TSC requirements are:
The only obligatory requirement refers to the measures taken to prohibit unauthorized access.
The amount of uptime your service is contractually obligated to adhere to.
The accuracy, consistency, and efficiency of manipulating data on behalf of your client.
Ensuring that access to data is limited to authorized users.
How your organization processes and retains personal information, and the policies involved in sharing it.
To understand the full extent of SOC 2 and how to determine the scope of your SOC 2 audit, it’s important to understand the Trust Services Criteria and how they can assess the risk and opportunities associated with the information security of an organization.
SOC 2 security controls list: The common criteria controls
As mentioned earlier, organizations are given full autonomy over which TSC they develop controls for as well as what those controls consist of. Perhaps confidentiality and availability are some of your organization’s core principles and operations. Your organization would prioritize developing all necessary controls for these TSCs. In short, your organization only implements the controls that are relevant to its operations, under the TSC included in your scope. However, the one TSC that isn’t optional, is Security. Security controls are essential and an obligatory requirement for all service organizations, which is why we’d like to focus on some controls to keep in mind when developing your controls list, relating to Security.
Logical (technological) and Physical Access Controls
This refers to the application of technological and physical safeguards. Its primary purpose is to protect information assets through security software, data encryption, infrastructures, or any other access control that best fits your organization. Within a SaaS company, the primary purpose of logical access controls is to authenticate and authorize access within computer information systems.
Authentication is a widely-accepted logical access control. However, as technology advances, it’s safe to assume that traditional password authentication doesn’t cut it anymore. With greater threats constantly developing within cybersecurity, password authentication lacks a strong enough identity check.
With each passing year, authentication strategies are becoming more complex, and more advanced protocols and processes are preferred among service organizations. This allows greater certainty in the identity of those who access system resources.
Examples of logical access controls:
- Network firewalls
- Passwords with two-step verification
- Intrusion detection systems
- Data encryption
Examples of physical access controls:
- Perimeter security
- Employee verification
- CCTV systems
- Physical or electronic locks
Change Management Controls
The change management process is considered a part of the IT general controls in any service organization. It includes standardized processes that authorize, regulate and approve any and all changes made to data, software, or infrastructure. It also includes analyzing and confirming whether or not each change is meeting its predetermined objectives.
Examples of change management controls:
- Patch updates
- A code repository tool for version control
- A ticketing system
System Operation Controls
Can you accurately detect and identify new vulnerabilities? Is there any deviation or abnormalities, and do you have a system in place to detect and mitigate any and all risks associated? These controls refer to the consistent monitoring of any changes within the service organization that may lead to fresh vulnerabilities.
Examples of System operation controls:
- Incident response protocols
- Threat detection
- Root cause analysis
A popular and comprehensive outsourced program that is frequently used as a control for system operation is managed detection and response (MDR), which covers all of the above.
Risk Mitigation Controls
This control involves the implementation of successful risk mitigation processes. These controls are responsible for identifying and preventing potential losses from risks before they become definite security breaches.
Example of risk mitigation controls:
- A comprehensive threat and vulnerability management program
In closing, it’s important to understand that although SOC 2 controls may not seem as straightforward to implement as one may wish, it is ultimately to benefit the security of the organization. However, that doesn’t mean that you’re left in the dark when it comes to implementing the right SOC 2 controls – not if we can help it.
SOC 2 compliance software: Is there an easier way to do SOC 2 compliance?
As you’re probably aware, there are no shortcuts or easy formulas you can copy and CTRL+V when it comes to SOC 2 compliance. However, when it comes to implementing the right controls, we’ve got you covered! Our SOC 2 superhero team develops a controls list customized to your organization and advises why it is best to include some and leave some out of your scope.
Manual compliance can be costly, tedious, time-consuming, and frequently contain human error. Some risks aren’t worth taking. With the right SOC 2 automation software, you can streamline your SOC 2 compliance and receive a list of controls customized to your organization.
At Scytale, we believe that with an intentional strategy, smart technology, professional input on what to avoid and where to put your focus, you can simplify SOC 2 and get compliant 90% faster. Take a look at just how we did this for our customers!