A SOC 2 audit evaluates your organization's controls across five Trust Service Criteria. This comprehensive control list provides detailed guidance on implementing and documenting each control to achieve successful SOC 2 compliance.
Understanding SOC 2 Controls
SOC 2 controls are policies, procedures, and practices designed to address the Trust Service Criteria (TSC) objectives. The American Institute of CPAs (AICPA) framework provides the foundation, but controls are tailored to each organization's unique environment, technology stack, and risk profile.
Security Controls (Common Criteria - Mandatory for All SOC 2 Audits)
Security is the foundation of SOC 2 compliance. These controls must be implemented by all organizations seeking SOC 2 certification.
CC1: Control Environment
Objective: Establish a strong foundation of governance, ethics, and oversight.
Control Activities:
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Board Oversight and Governance Structure
- Formally documented governance structure
- Board or equivalent oversight function
- Regular review of security and compliance matters
- Defined roles and responsibilities for security
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Code of Conduct and Ethics
- Written code of conduct distributed to all employees
- Annual acknowledgment of code of conduct
- Ethics training for new hires and annually
- Reporting mechanism for ethics violations
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Management Structure and Accountability
- Clearly defined organizational hierarchy
- Security roles assigned with specific accountability
- Performance reviews include security responsibilities
- Escalation paths for security issues
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Competence and Capability
- Job descriptions include security competencies
- Background checks for employees in sensitive roles
- Skills assessments during hiring
- Ongoing professional development
CC2: Communication and Information
Objective: Ensure relevant information is communicated internally and externally in a timely manner.
Control Activities:
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Internal Communication Processes
- Regular all-hands meetings covering security topics
- Security newsletter or communication channel
- Change notification processes
- Incident communication protocols
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External Communication
- Customer communication for security events
- Vendor management and communication
- Regulatory reporting as required
- Transparency in breach notification
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Information Quality
- Data accuracy and completeness standards
- Regular review of critical information
- Version control for documentation
- Data retention and archival policies
CC3: Risk Assessment
Objective: Identify, assess, and respond to risks that could affect the organization's objectives.
Control Activities:
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Risk Identification Process
- Annual comprehensive risk assessment
- Identification of internal and external threats
- Assessment of fraud risk
- Evaluation of technology and infrastructure risks
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Risk Analysis and Prioritization
- Risk scoring methodology (likelihood and impact)
- Risk register maintenance
- Risk owner assignment
- Regular review and update of risk assessments
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Risk Response
- Risk treatment plans (accept, mitigate, transfer, avoid)
- Control implementation for high-priority risks
- Monitoring of risk remediation
- Risk acceptance documentation by management
CC4: Monitoring Activities
Objective: Establish ongoing and periodic monitoring to assess control effectiveness.
Control Activities:
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Ongoing Monitoring
- Real-time security monitoring (SIEM, IDS/IPS)
- Automated alerting for anomalies
- Dashboard and metrics tracking
- Continuous vulnerability scanning
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Periodic Assessments
- Quarterly access reviews
- Annual internal audits
- Third-party penetration testing
- Independent control testing
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Deficiency Remediation
- Tracking system for identified deficiencies
- Remediation timelines based on severity
- Verification of remediation effectiveness
- Regular reporting to management
CC5: Control Activities
Objective: Implement specific policies and procedures to mitigate risks.
Control Activities:
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Technology Controls
- Change management procedures
- Configuration management
- Patch management
- Backup and recovery processes
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Access Controls
- User provisioning and deprovisioning
- Periodic access reviews
- Least privilege principle enforcement
- Segregation of duties
CC6: Logical and Physical Access Controls
Objective: Restrict access to information assets and facilities to authorized users.
Control Activities:
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User Access Management
- Formal access request and approval process
- Unique user credentials for each person
- Multi-factor authentication (MFA)
- Strong password requirements
- Automated deprovisioning upon termination
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Privileged Access Management
- Separate accounts for privileged access
- MFA required for privileged access
- Logging of all privileged activities
- Quarterly review of privileged users
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Physical Security
- Badge access systems for facilities
- Video surveillance of critical areas
- Visitor logs and escort procedures
- Equipment inventory tracking
- Secure disposal of hardware
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Network Security
- Firewall rules and policies
- Network segmentation
- VPN for remote access
- Intrusion detection and prevention
- Wireless network security
CC7: System Operations
Objective: Manage system operations effectively to support security and availability.
Control Activities:
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Capacity and Performance Management
- Resource utilization monitoring
- Capacity planning processes
- Performance testing
- Scalability assessments
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Incident Management
- Documented incident response plan
- Incident detection and classification
- Response and containment procedures
- Post-incident review and lessons learned
- Tabletop exercises at least annually
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Vulnerability Management
- Automated vulnerability scanning
- Risk-based remediation timelines
- Exception tracking and approval
- Third-party security assessments
CC8: Change Management
Objective: Manage changes to information systems in a controlled manner.
Control Activities:
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Change Request and Approval
- Formal change request process
- Management approval for significant changes
- Testing requirements before production
- Emergency change procedures
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Change Documentation
- Change logs with details and approvals
- Rollback plans for changes
- Configuration baseline documentation
- Version control for code and infrastructure
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Change Communication
- Notification to affected stakeholders
- Maintenance windows scheduled
- Post-implementation review
- Change calendar visibility
CC9: Risk Mitigation
Objective: Implement specific controls to address identified risks and threats.
Control Activities:
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Malware Protection
- Endpoint protection deployed on all devices
- Automated signature updates
- Regular malware scans
- Email filtering and scanning
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Data Loss Prevention
- DLP tools for sensitive data
- Monitoring of data exfiltration attempts
- Encryption of data in transit and at rest
- Data classification policies
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Security Training and Awareness
- Annual security awareness training for all employees
- Phishing simulation exercises
- Role-specific security training
- New hire security onboarding
Availability Controls (TSC - Optional, if applicable to your business)
If your organization commits to availability in customer agreements or your service depends on uptime guarantees, these controls apply.
A1: Availability Performance
Objective: Meet availability commitments and service level agreements.
Control Activities:
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SLA Monitoring and Reporting
- Defined uptime targets (e.g., 99.9%)
- Real-time availability monitoring
- Automated incident detection
- Regular reporting against SLAs
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Capacity Management
- Resource usage tracking and forecasting
- Proactive capacity planning
- Load testing for scalability
- Infrastructure redundancy
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Business Continuity and Disaster Recovery
- Documented BC/DR plans
- Regular backup procedures
- Tested recovery processes
- Failover capabilities
- Annual BC/DR testing
Processing Integrity Controls (TSC - Optional)
Processing integrity is critical for organizations where accurate, complete, and timely data processing is essential (e.g., financial services, payment processors).
PI1: Processing Quality
Objective: Ensure data processing is complete, valid, accurate, timely, and authorized.
Control Activities:
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Data Validation Controls
- Input validation at point of entry
- Data type, format, and range checks
- Automated error detection
- Duplicate detection mechanisms
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Processing Accuracy
- Transaction reconciliation processes
- Batch processing controls
- Automated testing of processing logic
- Error handling and reprocessing
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Processing Completeness
- Sequence number checking
- Transaction logging
- End-to-end processing verification
- Missing transaction detection
Confidentiality Controls (TSC - Optional)
Confidentiality applies to organizations that handle information designated as confidential by customers or internal classification.
C1: Confidentiality Protection
Objective: Protect confidential information from unauthorized disclosure.
Control Activities:
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Data Classification
- Documented classification scheme (e.g., Public, Internal, Confidential, Restricted)
- Classification labeling requirements
- Employee training on classification
- Regular review of classification
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Encryption
- Encryption of confidential data at rest (AES-256)
- Encryption of data in transit (TLS 1.2+)
- Key management procedures
- Regular encryption audits
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Confidential Data Handling
- Secure transmission protocols
- Restricted access to confidential data
- Non-disclosure agreements (NDAs)
- Confidential data disposal procedures
Privacy Controls (TSC - Optional)
Privacy controls apply to organizations that collect, use, retain, disclose, or dispose of personal information.
P1: Notice and Communication
Control Activities:
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Privacy Notice
- Published privacy policy
- Notice at point of collection
- Clear description of data use
- Regular review and updates
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Consent Management
- Explicit consent for data collection
- Opt-in/opt-out mechanisms
- Consent tracking and documentation
- Ability to withdraw consent
P2: Choice and Consent
Control Activities:
- Data Subject Rights
- Process for data access requests
- Data correction procedures
- Data deletion capabilities
- Data portability mechanisms
P3: Collection and Retention
Control Activities:
- Data Minimization
- Collection limited to necessary data
- Purpose specification
- Retention period definitions
- Automated data deletion
P4: Access and Security
Control Activities:
- Access to Personal Information
- Role-based access to personal data
- Logging of access to personal information
- Regular access reviews
- Encryption of personal data
P5: Disclosure to Third Parties
Control Activities:
- Third-Party Data Sharing
- Documented data sharing agreements
- Consent for third-party sharing
- Due diligence on third-party recipients
- Contractual obligations for data protection
P6: Quality and Integrity
Control Activities:
- Data Accuracy
- Processes to maintain data accuracy
- Data validation upon collection
- Mechanisms for users to update their data
- Regular data quality reviews
P7: Monitoring and Enforcement
Control Activities:
- Privacy Compliance Monitoring
- Regular privacy audits
- Incident response for privacy breaches
- Training on privacy obligations
- Privacy impact assessments for new systems
Creating Your Control List
To create a customized control list for your organization:
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Start with Security (Common Criteria): All SOC 2 audits require the Security criteria. Ensure you have controls for CC1 through CC9.
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Add Applicable Trust Service Criteria: Based on your business commitments, add Availability, Processing Integrity, Confidentiality, and/or Privacy controls.
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Tailor to Your Environment: Customize each control to reflect your specific technologies, processes, and risk profile.
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Document Control Objectives and Activities: For each control, clearly document:
- Control objective
- Control activities and procedures
- Responsible parties
- Frequency of execution
- Evidence of operation
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Map to Your Technology Stack: Link each control to the specific systems, tools, and platforms where it's implemented (e.g., "MFA enforced via Okta").
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Prepare for Evidence Collection: For each control, identify what evidence will be collected for the audit (e.g., screenshots, logs, reports, policies).
Conclusion
This comprehensive control list serves as a roadmap for your SOC 2 journey. Remember, the exact controls you implement will depend on your organization's unique circumstances, technology environment, and the specific Trust Service Criteria you're pursuing. Work closely with your auditor to ensure your control set adequately addresses your risks and meets the AICPA framework requirements.