Control objectives are the foundation of SOC 2 compliance. They represent the high-level goals that your organization's security and operational controls must achieve. This guide breaks down each control objective within the AICPA Trust Service Criteria framework to help you build a comprehensive compliance program.
Understanding Control Objectives vs. Controls
Before diving into specific objectives, it's important to understand the hierarchy:
- Trust Service Criteria (TSC): The five categories (Security, Availability, Processing Integrity, Confidentiality, Privacy)
- Control Objectives: High-level goals within each TSC (e.g., "restrict access to authorized users")
- Control Activities: Specific policies, procedures, and practices that achieve the objectives (e.g., "implement multi-factor authentication")
Your auditor will evaluate whether your control activities effectively achieve the stated control objectives.
Common Criteria: Security (Mandatory)
All SOC 2 audits must address the Security criteria, which consists of nine control objective categories (CC1-CC9).
CC1: Control Environment
Primary Objective: Establish and maintain an environment that supports the achievement of system objectives, including security commitments.
Specific Objectives:
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Governance and Oversight
- Demonstrate commitment to integrity and ethical values
- Exercise oversight responsibility for the design and operation of controls
- Establish structures, reporting lines, and appropriate authorities and responsibilities
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Competence and Accountability
- Demonstrate commitment to competence in security roles
- Hold individuals accountable for their control responsibilities
- Attract, develop, and retain competent individuals
Why It Matters: The control environment sets the "tone at the top." Without strong governance and accountability, even the best technical controls will be ineffective.
CC2: Communication and Information
Primary Objective: Ensure that information necessary to support the functioning of controls is obtained, generated, used, and communicated in a timely manner.
Specific Objectives:
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Relevant Information
- Obtain or generate relevant, quality information to support control functioning
- Communicate information internally to support control objectives
- Communicate with external parties regarding matters affecting control functioning
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Reporting Lines and Methods
- Provide separate communication lines for reporting deficiencies
- Select and develop communication methods appropriate to the audience
Why It Matters: Controls can't function if people don't have the right information at the right time. This includes knowing what's expected of them and having channels to report issues.
CC3: Risk Assessment
Primary Objective: Identify, analyze, and respond to risks that could affect the achievement of system objectives.
Specific Objectives:
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Risk Identification
- Specify objectives with sufficient clarity to enable identification of risks
- Identify and assess risks that could affect system objectives
- Consider fraud risk when assessing risks
- Identify and assess changes that could significantly impact controls
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Risk Response
- Analyze risks to determine how they should be managed
- Respond to risks by implementing control activities
Why It Matters: You can't protect what you don't know is at risk. A robust risk assessment ensures your controls are aligned with actual threats to your systems and data.
CC4: Monitoring Activities
Primary Objective: Monitor the effectiveness of controls and take corrective action when necessary.
Specific Objectives:
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Ongoing and Periodic Evaluations
- Conduct ongoing and/or separate evaluations to verify controls are present and functioning
- Evaluate and communicate control deficiencies in a timely manner
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Continuous Improvement
- Establish baseline performance metrics
- Monitor controls for effectiveness
- Remediate deficiencies in a timely manner
Why It Matters: Controls degrade over time or become ineffective as your environment changes. Monitoring ensures you catch and fix issues before auditors (or attackers) find them.
CC5: Control Activities
Primary Objective: Deploy control activities to mitigate risks to the achievement of objectives.
Specific Objectives:
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Selection and Development
- Select and develop control activities that contribute to mitigation of risks
- Select and develop general technology controls to support the achievement of objectives
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Policies and Procedures
- Deploy control activities through policies that establish expectations
- Deploy control activities through procedures that put policies into action
Why It Matters: This is where strategy meets execution. Control activities are the tangible actions your organization takes to protect its systems and data.
CC6: Logical and Physical Access Controls
Primary Objective: Limit access to information, systems, and facilities to authorized users.
Specific Objectives:
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User Access Management
- Grant access based on job responsibilities (least privilege principle)
- Identify and authenticate users before granting access
- Remove or modify access in a timely manner when roles change or employment ends
- Review user access rights periodically
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Privileged Access
- Restrict and monitor privileged access
- Manage and monitor access to sensitive information
- Implement multi-factor authentication for privileged and remote access
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Physical Security
- Restrict physical access to facilities, equipment, and other assets
- Monitor and log physical access
- Protect assets from environmental threats (fire, flood, etc.)
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Network Security
- Restrict access to networks and network services
- Protect boundaries between network segments
- Monitor network traffic for unauthorized access
Why It Matters: Unauthorized access is one of the most common attack vectors. Strong access controls are your first line of defense.
CC7: System Operations
Primary Objective: Ensure systems operate as designed to support the achievement of entity objectives.
Specific Objectives:
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Capacity and Performance
- Manage system capacity to meet processing requirements
- Monitor system performance
- Address processing deviations from expectations
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Incident Management
- Detect, respond to, and recover from incidents
- Implement backup and recovery procedures
- Test backup and recovery procedures periodically
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Vulnerability Management
- Identify and assess vulnerabilities
- Design and implement controls to mitigate vulnerabilities
- Remediate identified vulnerabilities in a timely manner
Why It Matters: Secure systems that don't operate reliably fail to meet customer commitments. Operational excellence is critical to both security and business continuity.
CC8: Change Management
Primary Objective: Manage changes to systems in a controlled, secure manner.
Specific Objectives:
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Change Authorization and Approval
- Authorize changes prior to implementation
- Design and develop changes according to security requirements
- Document changes and their impact on security controls
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Change Testing and Deployment
- Test changes before deployment to production
- Manage emergency changes with compensating controls
- Document and communicate changes to affected parties
Why It Matters: Uncontrolled changes are a leading cause of security incidents and outages. Structured change management balances the need for agility with the need for stability and security.
CC9: Risk Mitigation
Primary Objective: Implement specific control activities to address identified security risks.
Specific Objectives:
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Malware and Malicious Code Protection
- Deploy anti-malware tools and keep them updated
- Scan for malware regularly
- Restrict the execution of unauthorized software
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Data Protection
- Encrypt sensitive data in transit and at rest
- Implement data loss prevention (DLP) controls
- Manage cryptographic keys securely
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Security Awareness
- Train employees on security policies and procedures
- Conduct security awareness training regularly
- Test security awareness through simulations (e.g., phishing tests)
Why It Matters: These are the specific, tactical controls that directly address the most common attack vectors and data protection requirements.
Availability (Additional Criteria - Optional)
If your organization commits to availability in customer contracts or SLAs, you must address these control objectives.
A1: Availability
Primary Objective: Ensure the system is available for operation and use as committed or agreed upon.
Specific Objectives:
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System Availability Performance
- Monitor and measure system availability against defined targets
- Communicate availability metrics to stakeholders
- Investigate and address availability incidents
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Recovery and Resilience
- Implement business continuity and disaster recovery plans
- Test recovery procedures periodically
- Maintain redundant infrastructure where appropriate
- Implement failover capabilities
Why It Matters: If your business promises 99.9% uptime, you need controls to deliver and measure that commitment.
Processing Integrity (Additional Criteria - Optional)
Processing integrity is essential for organizations where data accuracy, completeness, and timeliness are critical (e.g., financial services, payment processing).
PI1: Processing Integrity
Primary Objective: Ensure system processing is complete, valid, accurate, timely, and authorized.
Specific Objectives:
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Input Validation and Authorization
- Validate inputs for completeness, accuracy, and authorization
- Detect and prevent invalid inputs from being processed
- Authorize transactions before processing
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Processing Accuracy and Completeness
- Process data completely and accurately
- Detect and correct processing errors
- Ensure data is processed in a timely manner
- Verify processing logic for accuracy
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Output Distribution
- Distribute outputs to authorized parties only
- Ensure outputs are complete and accurate
- Protect outputs from unauthorized alteration
Why It Matters: In industries like finance or healthcare, processing errors can have significant legal, financial, and safety consequences.
Confidentiality (Additional Criteria - Optional)
Confidentiality applies when your organization handles information that must be protected from unauthorized disclosure.
C1: Confidentiality
Primary Objective: Protect information designated as confidential from unauthorized disclosure.
Specific Objectives:
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Data Classification
- Identify and classify confidential information
- Communicate classification policies to relevant personnel
- Review and update classifications periodically
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Confidential Data Protection
- Encrypt confidential data in transit and at rest
- Restrict access to confidential information based on need-to-know
- Monitor and log access to confidential information
- Securely dispose of confidential information when no longer needed
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Third-Party Protection
- Protect confidential information shared with third parties through contracts
- Monitor third-party handling of confidential information
Why It Matters: Breach of confidential information (trade secrets, proprietary data, sensitive customer data) can result in competitive harm, legal liability, and customer trust erosion.
Privacy (Additional Criteria - Optional)
Privacy applies to organizations that collect, use, retain, disclose, or dispose of personal information.
P1: Notice and Communication
Primary Objective: Provide notice about privacy practices and communicate with data subjects.
Specific Objectives:
- Provide clear and accessible privacy notices
- Describe data collection, use, retention, disclosure, and disposal practices
- Update privacy notices when practices change
- Make notices available at or before the point of collection
P2: Choice and Consent
Primary Objective: Allow data subjects to make informed choices and provide consent for data processing.
Specific Objectives:
- Obtain explicit consent for data collection and use
- Provide choices about data collection, use, and disclosure
- Respect choices and consent decisions
- Provide mechanisms to withdraw consent
P3: Collection
Primary Objective: Collect personal information consistent with stated purposes and with data subject consent.
Specific Objectives:
- Limit collection to information necessary for stated purposes
- Collect personal information by lawful and fair means
- Obtain consent prior to collection, where required
P4: Use, Retention, and Disposal
Primary Objective: Use, retain, and dispose of personal information consistent with stated purposes and legal requirements.
Specific Objectives:
- Use personal information only for stated purposes
- Retain personal information only as long as necessary
- Dispose of personal information securely when no longer needed
P5: Access
Primary Objective: Provide data subjects with access to their personal information.
Specific Objectives:
- Provide individuals with access to their personal information
- Allow individuals to request corrections to inaccurate information
- Respond to access requests in a timely manner
P6: Disclosure to Third Parties
Primary Objective: Disclose personal information to third parties only with consent and with appropriate protection.
Specific Objectives:
- Obtain consent before disclosing personal information to third parties
- Disclose personal information only to parties who provide equivalent protection
- Hold third parties accountable through contracts
- Monitor third-party compliance
P7: Quality
Primary Objective: Maintain accurate, complete, and relevant personal information.
Specific Objectives:
- Verify accuracy of personal information upon collection
- Provide mechanisms for individuals to update their information
- Conduct periodic reviews of data quality
P8: Monitoring and Enforcement
Primary Objective: Monitor compliance with privacy policies and take corrective action.
Specific Objectives:
- Monitor compliance with privacy commitments
- Investigate and respond to privacy complaints
- Impose sanctions for privacy violations
- Conduct privacy impact assessments for new systems
Why It Matters: With regulations like GDPR, CCPA, and others, privacy is not just good practice—it's legally required. Privacy controls protect both your customers and your organization from regulatory penalties.
Implementing Control Objectives in Your Organization
To effectively implement SOC 2 control objectives:
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Start with Risk Assessment: Understand your specific risks to determine which control objectives are most critical for your environment.
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Map Objectives to Activities: For each objective, define specific control activities (policies, procedures, technologies) that will achieve the objective.
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Assign Ownership: Each control objective should have a designated owner responsible for ensuring the objective is met.
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Document Everything: Clearly document how each control objective is being met through your control activities.
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Collect Evidence: Plan how you'll demonstrate to auditors that each objective has been achieved.
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Monitor and Measure: Establish metrics and monitoring processes to verify ongoing achievement of objectives.
Conclusion
Control objectives provide the strategic framework for your SOC 2 compliance program. By understanding each objective and thoughtfully designing control activities to achieve them, you build a robust, auditable program that not only satisfies auditors but genuinely strengthens your security posture and protects your customers' data.