SOC2 - Additional Trust Services Criteria

Introduction

If your organization provides cloud-based or data-driven services, you are likely familiar with SOC 2. It is one of the most respected security frameworks for service organizations. SOC 2 reports are based on five Trust Services Criteria(TSC) developed by the AICPA (American Institute of Certified Public Accountants). Most organizations begin with the security category, but the framework also includes availability, Confidentiality, Processing Integrity, and privacy.

In our previous blog, “SOC 2 – A Practical Approach,” we examined the effective implementation of SOC 2. We also covered the privacy criteria in detail in a separate article. This blog focuses on the additional Trust Services Criteria beyond security and privacy, specifically Availability, Confidentiality, and Processing Integrity. We will also share tips to implement these efficiently.

Let’s now break down additional trust services criteria, what they mean, and how you can apply them.

Additional Availability Criteria

The Availability criteria evaluate whether your systems are accessible and usable as promised in service-level agreements (SLAs). It’s not just about being online 24/7; it’s about planning for disruptions, monitoring performance, and recovering quickly whenever problems occur.

To meet this particular criterion, organizations should show that they have:

• Clearly defined availability goals

• Performance monitoring systems

• Disaster recovery and business continuity plans

• Incident response strategies

For example, if your software is used by businesses that rely on it daily for their operations, any unexpected downtime could impact their work. Meeting the Availability criteria helps reduce that risk by demonstrating you have processes in place to maintain uptime and restore service quickly when needed.

Your controls may include system redundancy, automated failover, alerting tools, and regularly tested recovery plans. You should also define your Recovery Time Objective (RTO) and Recovery Point Objective (RPO), ensuring these are achievable within your existing infrastructure.

Adopting the Availability criteria shows clients you take reliability seriously, not just security. It assures them that your business continuity is designed and tested, not just documented.

Confidentiality Criteria

The Confidentiality criteria are about protecting sensitive business information that should not be disclosed to unauthorized parties. This includes customer-related data, intellectual property, financial information, pricing structures, and other internal business processes.

In today’s digital environment, businesses frequently share confidential information with vendors and third-party entities. If you handle sensitive data, even if it’s not considered personal data, you should consider adding Confidentiality to your SOC 2 scope.

To meet this criterion, organizations need to show that they can:

1. Restrict access to confidential data based on role or need

2. Utilize encryption to protect data both in transit and at rest.

3. Safe and secure disposal of data whenever it’s no longer needed

4. Monitor and log access to confidential information

5. Enforce non-disclosure agreements (NDAs) and employee training

Data classification is also important here. You must be able to distinguish what is confidential and ensure it receives the right level of protection. Tools such as Data Loss Prevention (DLP) software, access control lists, and audit logs are commonly used to support compliance with this criterion.

Meeting the Confidentiality criteria helps your clients trust that their business secrets, plans, or sensitive contracts are safe with your company. It also reduces your own risk of internal leaks or accidental data exposure.

Processing Integrity Criteria

The Processing Integrity criteria ensure that your systems process data accurately and in a timely manner. It’s especially important for companies that offer platforms where users depend on data accuracy, like payment processors, payroll systems, analytics tools, or order fulfillment services.

This criterion assesses whether your system delivers accurate results as intended, without delays or unauthorized modifications. It includes controls that prevent data entry errors, system bugs, or unauthorized processing activities.

Organizations that want to meet the Processing Integrity criterion need to implement:

• Input validation checks to make sure the data entered is accurate

• Quality control processes to monitor output accuracy

• Error handling and exception-tracking

• Audit logs to trace transactions and system behavior

• Access controls to prevent unauthorized system changes

For example, if your platform generates invoices or calculates totals, you must demonstrate that the data inputs are valid and that the calculations are accurate. Even a small bug or input error could result in a financial mistake, affecting clients’ trust and possibly causing legal exposure.

It’s also important to have automated testing and rollback procedures in case a deployment causes data processing issues. Version control systems, test cases, and monitoring dashboards help maintain the integrity of your operations.

Processing Integrity is not required for every SOC 2 report, but if your system’s core function involves transactional or decision-making operations, it’s worth including.

Tips for Smooth Implementation

Implementing additional Trust Services Criteria in your SOC 2 program can look like a difficult task at first, but following a systematic approach makes it manageable. Here are some key tips to help you do it smoothly:

Understand which criteria apply to you.

Not every organization needs all five criteria. Choose the ones based on your industry, customer expectations, and service offerings. For example, if you do not process user data but host static content, the principle of processing integrity may not apply.

Start with a readiness assessment.

A gap analysis helps you identify which controls are already in place and which need to be developed. It also clarifies the additional documentation or procedures that will be necessary to meet the new criteria.

Map your controls to each criterion.

Create a clear matrix showing how each control satisfies a specific criterion. This simplifies audits and keeps your compliance efforts organized and streamlined. Many security platforms and compliance tools help automate this mapping.

Document everything thoroughly

Policies, procedures, and evidence must be written and accessible. Poor documentation is a common reason audits fail or are delayed.

Engage your internal teams.

Involve IT, HR, engineering, and operations early in the process. Their continuous participation ensures proper controls are implemented correctly and consistently. Regular employee awareness and training also reduce accidental violations.

Review third-party dependencies

If your system heavily relies on other services, such as AWS, Stripe, or Google Cloud, ensure that those vendors meet similar criteria. Include their SOC reports in your audit file and define how responsibilities are shared.

Monitor continuously, not just before the audit.

Many companies make the mistake of preparing for SOC 2 only during audit season. Utilize automation to monitor and control performance throughout the year continuously. This keeps your organization always audit-ready.

Schedule internal audits or dry runs.

Simulating a trial audit before the real one helps identify potential issues. It also prepares your teams to respond efficiently to requests coming from your auditor.

Leverage frameworks like ISO or NIST

If you are already compliant with ISO 27001 or NIST CSF, ensure that you reuse those controls wherever applicable. SOC 2 does not require reworking your entire compliance structure.

Conclusion

Expanding your SOC 2 audit to include Availability, Confidentiality, and processing integrity demonstrates to clients that your organization is committed to more than just basic security. Availability confirms your systems can withstand outages and stay online as needed. Confidentiality ensures that you can effectively protect sensitive data from potential leaks and unauthorized access. Processing Integrity assures your clients that your systems can produce accurate results.

To effectively implement these criteria, start with a quick review session. SOC2 is more than a checklist. It’s an ongoing commitment done for your customers, your operations, and your reputation.