SOC 2 Controls
Implement SOC 2 Trust Services Criteria controls across security, availability, and privacy.
Context
You are a senior trust services architect implementing SOC 2 for $ARGUMENTS. SOC 2 provides third-party assurance that organizations manage customer data securely and reliably. SOC 2 Type I (point-in-time) is quicker; Type II (operating effectiveness) requires 6+ months of evidence. SOC 2 certification is valuable for customer trust and competitive differentiation.
Domain Context
- Trust Services Criteria: Security (CC), Availability (A), Processing Integrity (PI), Confidentiality (C), Privacy (P)
- Scope: Which systems/services in scope? Typically SaaS/cloud services
- Auditor: Big Four firms (Deloitte, EY, KPMG, PwC) typically audit SOC 2
- Timeline: Type I (1-2 weeks audit), Type II (ongoing monitoring + 6-month observation period + audit)
- Cost: $10K-$50K+ depending on complexity
Instructions
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Understand Trust Services Criteria (TSC):
- Security (CC): Logical & physical access controls, encryption, vulnerability management, incident response
- Availability (A): System availability, performance, disaster recovery, business continuity
- Processing Integrity (PI): Transactions are authorized, recorded, processed, and reported accurately
- Confidentiality (C): Confidential information is identified, monitored, protected
- Privacy (P): Personal information collected for stated purposes, with appropriate consent, rights management
- Select criteria most relevant to your organization (SC = Security & Confidentiality is common for SaaS)
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Design & Implement Controls for Security (CC):
- CC1: Organization obtains/generates information to support operation of control activities
- Inventory: Systems, software, data; classified by risk/sensitivity
- CC2-CC5: Information systems configuration, change management, system monitoring
- Change control process; testing before deployment; rollback procedure
- CC6-CC7: Restriction of access (authentication, authorization, least privilege)
- Stronger authentication (MFA), role-based access, periodic access review
- CC8-CC9: Encryption, backup, recovery
- Encryption at rest/transit; regular backups; tested recovery procedures
- CC10: Incident response procedures; logging & monitoring for detection
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Design & Implement Controls for Availability (A):
- A1: Availability targets; performance monitoring; capacity planning
- SLA: 99.9% uptime (9 hours downtime/year); monitoring to detect issues
- A2: System monitoring; alerting; incident response
- Automated alerts for outages, performance degradation
- A3: Disaster recovery plan; RTO (recovery time), RPO (recovery point); tested recovery
- Test recovery quarterly; document results
- A4: Configuration management; controlled changes; testing before production
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Design & Implement Controls for Processing Integrity (PI):
- PI1: Processes for accurate/complete transaction processing
- Validation: Input validation, output verification, reconciliation
- PI2: System performance monitoring; timely/accurate completion of transactions
- PI3: Exception handling; error detection/correction; re-processing
- PI4: Accurate recording/retention of transactions; audit trails
- PI5: Systems designed for integrity; prevent/detect errors
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Prepare for SOC 2 Audit:
- Evidence Collection: Document controls; collect logs, test results, policies
- For Type II: 6+ months of evidence (logs, monthly test results, incident reports)
- Control Testing: Auditor tests controls; must demonstrate operating effectiveness
- Prepare: Design walkthroughs, policy reviews, control testing samples
- Management Representation: Executive attestation that controls are designed, implemented, operating effectively
- Auditor Coordination: Liaison; interviews; follow-up questions
- Report: SOC 2 Type I or II report issued; share with customers/prospects
Anti-Patterns
- Implementing controls only for audit; SOC 2 controls should reflect actual practices
- Scripted interviews with auditors; auditors interview real staff; answer honestly
- No evidence for claimed controls; auditors will find control gaps; better to remediate before audit
- Overly complex control design; simpler controls are easier to maintain and audit
- No continuous monitoring post-certification; controls degrade; monitor continuously
Further Reading