SOC2 compliance: A checklist

SOC 2 (Service Organization Control 2) is an auditing standard developed by the American Institute of CPAs (AICPA) that evaluates how well service organizations manage and protect customer data. It focuses on five key trust service criteria: security, availability, processing integrity, confidentiality, and privacy. The framework is specifically designed for technology and cloud computing companies that store, process, or transmit customer information.

There are two types of SOC 2 reports: Type I and Type II. Type I reports assess whether a company's controls are properly designed and implemented at a specific point in time. Type II reports are more comprehensive, examining the operational effectiveness of these controls over a period of time, typically six to twelve months.

SOC 2 compliance demonstrates to customers, partners, and stakeholders that an organization takes data security seriously and has implemented appropriate safeguards. While not legally required, SOC 2 certification has become increasingly important for businesses seeking to build trust and meet the security requirements of enterprise clients. The audit process involves working with an independent CPA firm to assess controls, identify gaps, and ultimately receive a report that can be shared with interested parties under non-disclosure agreements.

SOC2 compliance steps

Steps for SOC 2 compliance

1. Scope definition and gap analysis

Begin by determining which Trust Service Criteria (TSC) apply to your organization and conducting a thorough gap analysis. Define your system boundaries, identify what data flows through your systems, and assess current security controls against SOC 2 requirements. This foundational step establishes the audit scope and reveals areas requiring immediate attention before engaging with auditors.

2. Control implementation and documentation

Develop and implement security controls that address the identified gaps from your analysis. Create comprehensive policies, procedures, and documentation that demonstrate how your organization meets each relevant TSC requirement. This includes establishing formal security policies, incident response procedures, access management protocols, and vendor management frameworks that align with SOC 2 standards.

3. Evidence collection and monitoring

Establish systematic processes for collecting and maintaining evidence of control effectiveness over time. Implement continuous monitoring systems that track security metrics, log access attempts, document policy exceptions, and maintain audit trails. This ongoing documentation proves that controls are not only designed properly but are operating effectively throughout the audit period.

4. Audit execution and remediation

Engage a qualified CPA firm to conduct the formal SOC 2 audit, which will involve testing your controls and reviewing collected evidence. Address any findings or exceptions identified during the audit process through immediate remediation efforts. After receiving your SOC 2 report, establish processes for continuous improvement and preparation for subsequent audits to maintain compliance over time.

SOC 2 compliance checklist

• Establish Information Security Policies - Create comprehensive security policies covering areas like acceptable use, data handling, and incident response. Example: Develop a formal Information Security Policy that defines roles, responsibilities, and acceptable use standards, including specific guidelines for remote work and BYOD scenarios.
• Implement Access Controls and User Management - Deploy multi-factor authentication and role-based access controls across all systems. Example: Configure SSO with MFA for all employees accessing customer data systems, with quarterly access reviews to ensure former employees are deprovisioned and current employees have appropriate permissions.
• Deploy Continuous Monitoring and Logging - Establish comprehensive logging and monitoring for all critical systems and data access. Example: Implement SIEM tools that log all database queries, file access, and administrative actions, with automated alerts for suspicious activities like after-hours access or bulk data downloads.
• Create Incident Response Procedures - Develop formal incident response plans with clear escalation paths and communication protocols. Example: Establish a 24/7 incident response team with defined roles, including procedures for containing data breaches within 1 hour of detection and customer notification within 24 hours.
• Perform Regular Vulnerability Management - Conduct systematic vulnerability assessments and penetration testing on a regular schedule. Example: Schedule quarterly external penetration tests and monthly internal vulnerability scans, with requirements to remediate critical vulnerabilities within 48 hours and high-risk issues within 7 days.
• Maintain Vendor Risk Management Program - Assess and monitor third-party vendors who have access to your systems or customer data. Example: Require all vendors handling customer data to provide current SOC 2 reports, conduct annual security assessments, and maintain specific contractual requirements for data handling and breach notification.
• Establish Business Continuity and Disaster Recovery - Develop and test comprehensive backup and recovery procedures to ensure system availability. Example: Implement automated daily backups with quarterly disaster recovery tests, maintaining RTO of 4 hours and RPO of 1 hour, with documented procedures for failover to secondary data centers.
• Document Evidence Collection Processes - Create systematic procedures for collecting, organizing, and maintaining compliance evidence throughout the year. Example: Establish monthly evidence collection cycles that capture access logs, policy acknowledgments, training records, and control testing results in a centralized compliance management system.

Common challenges

Organizations pursuing SOC 2 compliance encounter significant hurdles in the areas of control implementation, documentation, and ongoing maintenance. Many companies underestimate the complexity of designing and deploying the necessary internal controls to meet the trust service criteria, particularly when attempting to align these controls with existing business processes and technology infrastructure. The lack of clear, prescriptive requirements in SOC 2 can leave organizations uncertain about what specific measures they need to implement, leading to either over-engineering expensive solutions or falling short of auditor expectations.

Resource allocation and organizational readiness present another major challenge for SOC 2 compliance efforts. Companies often struggle to dedicate sufficient personnel, time, and budget to compliance initiatives while maintaining their core business operations. The cross-functional nature of SOC 2 requirements means that multiple departments must coordinate effectively, from IT and security teams to human resources and vendor management, which can create bottlenecks and communication gaps that delay compliance timelines.

The continuous nature of SOC 2 compliance creates long-term operational challenges that many organizations fail to anticipate. Unlike one-time certifications, SOC 2 requires sustained vigilance and regular evidence collection to demonstrate that controls are operating effectively over time. Organizations frequently find themselves unprepared for the ongoing monitoring, testing, and documentation requirements that extend well beyond the initial audit period, leading to compliance gaps that can jeopardize their certification status and customer relationships.

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Frequently asked questions

Q: What's the difference between SOC 2 Type I and Type II reports?

A: Type I reports assess whether a company's controls are properly designed and implemented at a specific point in time, while Type II reports are more comprehensive, examining the operational effectiveness of these controls over a period of time (typically six to twelve months).

Q: How long does the SOC 2 compliance process typically take?

A: The process involves four main steps: scope definition and gap analysis, control implementation and documentation, evidence collection and monitoring, and audit execution and remediation. Type II audits specifically require six to twelve months of demonstrated control effectiveness, though the entire process can take longer depending on your organization's readiness.

Q: What are the five trust service criteria that SOC 2 focuses on?

A: SOC 2 evaluates organizations based on five key trust service criteria: security, availability, processing integrity, confidentiality, and privacy. Not all organizations need to address every criterion - it depends on your specific business model and services.

Q: Is SOC 2 compliance legally required?

A: No, SOC 2 compliance is not legally required. However, it has become increasingly important for businesses seeking to build trust and meet the security requirements of enterprise clients, particularly for technology and cloud computing companies that handle customer data.

Q: What are the biggest challenges organizations face when pursuing SOC 2 compliance?

A: The three main challenges are: 1) Control implementation complexity and uncertainty about specific requirements, 2) Resource allocation and cross-departmental coordination difficulties, and 3) The ongoing nature of compliance that requires continuous monitoring, testing, and documentation beyond the initial audit period.