As a CISO who recently led an organisation through successful SOC 2 Type 1 and Type 2 audits, I’d like to share some insights and steps to help others on their journey toward SOC 2 attestation.
SOC 2 may not be for everyone (refer to my blog on compliance frameworks), but it can be useful for organisations dealing with sensitive customer data, particularly in SaaS, as it demonstrates a commitment to security, privacy, and data integrity. The journey toward SOC 2 attestation can be complex, but with careful planning and the right strategies, it’s achievable.
Understanding SOC 2 Type 1 vs. Type 2
- SOC 2 Type 1 examines the design of controls at a specific point in time, ensuring they are properly designed to meet the necessary trust service criteria.
- SOC 2 Type 2 evaluates the operational effectiveness of those controls over a period, usually between six to twelve months.
Both reports assess controls related to security, availability, confidentiality, processing integrity and privacy but Type 2 is considered more comprehensive as it covers performance over time.
The typical examination period is 12 months, however, it can be as short as 3 months depending on your requirements. While it’s possible to go straight to Type 2, I recommend doing the Type 1 first as it gives you a good baseline for control design effectiveness and can highlight any potential deficiencies early.
Choose an independent auditor with experience in SOC 2 and your industry. This is vital to ensure a smooth and efficient process. Partnering with a knowledgeable auditor early on, who provided guidance on industry standards and good practices.
Scoping and planning
Start by defining the scope of your audit. Understand which systems, processes, and locations will be included. SOC 2 is quite different from ISO 27001 or NIST CSF, for example, and scope definition becomes critically important. Work with your auditor on scoping, don’t keep it too wide unless absolutely necessary.
There’s also some degree of flexibility when it comes to Trust Services Criteria (TSCs): Security, Confidentiality and Availability are the baseline, with an option to add Privacy and Processing Integrity based on your needs and customer expectations.
Some experts recommend conducting a gap analysis to understand where your current controls might fall short. This helps in formulating an actionable plan to remediate any weaknesses before the audit begins. Although a sensible suggestion, I’d consider going straight into the SOC 2 Type 1 audit, depending on your level of experience.
Designing and implementing controls
The backbone of SOC 2 is your internal controls. These should address each of the five TSCs but focus heavily on security. Examples of critical controls include:
- Access Controls: Limiting who can access sensitive data (both employee and customer data) and implementing robust authentication processes.
- Data Backup and Recovery: Ensuring regular backups and a solid disaster recovery plan.
- Incident Response: Implementing a clear incident response plan to manage and mitigate security breaches.
Work with your auditor to select applicable controls.
Preparing for SOC 2 Type 1 audit
Once your controls are in place, your next step is the SOC 2 Type 1 audit. This audit focuses on whether the right controls are designed properly to achieve your security objectives. Preparation for this audit involves documentation of all policies, procedures, and technical controls, ensuring they are well-organised and auditable.
Be ready to demonstrate your environment’s security processes and document everything comprehensively—from HR policies to technical system logs.
Monitoring for SOC 2 Type 2
After successfully achieving Type 1, begin preparing for Type 2, which typically requires 3 – 12 months of data collection. Maintain ongoing monitoring of your controls and ensure they are functioning as intended over time. This is the operational part of the process, and appropriate tools for logging, monitoring, and alerting are critical.
During this time, ensure all security incidents are tracked, and responses are well-documented. External auditors will review this evidence to determine the effectiveness of your controls.
Building a culture of security
One of the biggest lessons for many companies is that SOC 2 isn’t just about passing an audit—it’s about embedding security into the company culture. From day one, make security part of your onboarding process, regular employee training, and leadership conversations.
Post-audit: maintaining compliance
Achieving SOC 2 attestation isn’t a one-time effort. Once you’ve passed the audit, continuous compliance is key. You will need to maintain the SOC 2 Type 2 program that involves an in-depth ongoing assessment of your control operating effectiveness. Regularly update your controls, especially as your product and infrastructure evolve.
The journey may be long, but the benefits of securing your products and services and building trust with your customers make it well worth the effort.
Cyber Security Leadership 