Creating Effective SOC 2 Controls: A Practical Guide
For those in the trenches of security, achieving SOC 2 compliance is more than just checking a box. It’s about establishing a framework of controls that not only meet the Trust Services Criteria (TSC) but also enhance the security of your systems. Writing effective SOC 2 controls is one of the most critical and often misunderstood parts of this process.
Whether you're well-versed in SOC 2 or just getting started, this guide will help you understand the essentials of drafting controls that not only meet compliance requirements but also serve to strengthen your overall security posture. Let’s dive into the what, why, and how of creating meaningful SOC 2 controls.
What Are SOC 2 Controls?
SOC 2 controls are the technical and procedural safeguards your organization implements to meet the Trust Services Criteria. These five criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy, require you to have specific controls in place to ensure your systems and data are protected from unauthorized access, downtime, errors, or misuse.
However, SOC 2 isn’t just about ticking boxes. Your controls must be measurable, repeatable, and auditable. In a SOC 2 Type 2 audit, auditors assess whether your controls are working effectively over time. This means your controls need to be clear, specific, and designed for continuous, reliable operation, not one-time actions.
Characteristics of Effective SOC 2 Controls
Creating effective controls isn’t as simple as writing statements. A good control is operational, measurable, and integral to your security infrastructure. Here’s what to keep in mind when drafting your controls:
Actionable: Vague or overly general controls won’t hold up during an audit. A good control specifies exactly what is being done, who is doing it, and how its effectiveness will be measured.
Testable: Your controls must be testable by auditors. This means they should have measurable outcomes. For instance, are logs reviewed regularly? Are access requests validated within a specified timeframe? The clearer and more measurable the control, the easier it is to prove that your systems are secure.
Repeatable: Controls should be part of an ongoing process, not a one-off action. This is where formalizing existing security practices is crucial. Your controls should be consistently executed over time, making sure your team can repeat the process reliably.
Writing Your SOC 2 Controls: Getting the Details Right
When drafting your SOC 2 controls, specificity is key. Vague controls won’t pass muster with auditors, while overly detailed ones can complicate the process. Striking the right balance is crucial.
For example, consider the following vague control: "The network is monitored."
This statement lacks the necessary details to be actionable or auditable.
A more specific and effective control would be: "Network traffic is monitored in real-time using a network monitoring tool. Logs are reviewed daily for anomalies, and any suspicious activity triggers an alert to the IT security team."
This version is clear and actionable. It specifies what’s being done, who is responsible, and how effectiveness is measured. Auditors can easily assess whether this control is being followed and operating as intended.
Leveraging Your Existing Systems
When it comes to SOC 2 compliance, it’s easy to feel overwhelmed by the extensive requirements. However, you already have many of the systems and processes in place. The key is to formalize and refine them to meet SOC 2’s standards.
Start by reviewing the Trust Services Criteria (TSC). Rather than just ticking off items on a checklist, think about how your current security measures align with these criteria. This will help you identify where your current controls meet the requirements and where adjustments may be needed.
For example, if you already have an intrusion detection system (IDS) in place to monitor for unauthorized network access, you don’t need to create a new control from scratch. Instead, document the use of the IDS for monitoring security threats, specify how alerts are generated, and clarify who is responsible for responding to those alerts. By doing this, you’re able to leverage your existing systems while ensuring full compliance with SOC 2.
The goal is to make your controls clear, actionable, and aligned with SOC 2’s requirements, so they can be effectively tested by auditors and demonstrate your commitment to security and compliance.
Ownership and Accountability: The Key to Successful Controls
SOC 2 compliance is a team effort. For controls to be effective, they must have clearly defined ownership. Assign individuals or teams responsible for implementing and ensuring the controls are functioning as intended.
For example, if your team is responsible for monitoring system availability, the Operations Team might manage uptime, while the Security Team manages real-time alerts. Clear ownership ensures accountability and guarantees someone will follow through to ensure the control is working.
This accountability makes the process more than just a compliance exercise, it becomes part of your everyday operations, integrating security into your workflow.
Testing and Refining Your Controls Before the Audit
Once your controls are drafted, the real work begins, testing. SOC 2 isn’t just about getting everything in place; it’s about making sure your controls are working effectively over time. Before your audit, run internal tests. Simulate a security incident to see if your IDS triggers the expected alerts or conduct a mock access review to ensure access controls are properly followed.
Testing early ensures you can catch and address issues before your auditor arrives. It also helps to fine-tune your controls and refine processes that might not be as strong as you thought. This proactive approach allows you to spot weaknesses early on and avoid scrambling at the last minute to fix problems.
Collaborate with Your Auditor
Though you won’t officially begin the audit until the designated date, it’s beneficial to involve your SOC 2 auditor early in the process. Share your drafted controls with them to get their feedback. While they won’t be able to conduct a full review until the audit, they can still help identify gaps or areas of concern.
This early collaboration can be crucial in ensuring your controls are designed correctly and will hold up under scrutiny. Your auditor might suggest adjustments or improvements that can make the audit process smoother and faster.
Conclusion: Creating a Resilient SOC 2 Control Framework
Drafting your SOC 2 controls isn’t just about meeting audit requirements, it’s about building an enduring framework that continuously strengthens your security posture. By focusing on specificity, ownership, and testing, you can create controls that stand up to the rigorous demands of a SOC 2 Type 2 audit, all while improving the overall security and reliability of your organization.
SOC 2 compliance may seem daunting, but it doesn’t have to be a one-time scramble. When you treat your controls as part of an ongoing, refined process, you’ll be in a stronger position to protect your systems and customers. And that’s a win for everyone.
