Implementing SOC 2 – A Practical Approach

Implementing SOC 2 – A Practical Approach

Published on July 10, 2025

Introduction

SOC 2, developed by the AICPA, helps service-oriented and tech firms ensure system integrity, data privacy, and security. While SOC 1 focuses on financial controls, SOC 2 assesses your organization’s security, availability, processing integrity, confidentiality, and privacy. It is particularly vital for cloud and SaaS providers managing customer information. This guide offers a practical roadmap for achieving SOC 2 compliance and improving your organization’s data protection practices.

The Trust Services Criteria

SOC 2 is based on five Trust Services Criteria:

  • Security: Protection against unauthorized access.

  • Availability: Ensuring systems are operational as agreed.

  • Processing Integrity: Ensuring system processing is valid, accurate, timely, and authorized.

  • Confidentiality: Safeguarding confidential information.

  • Privacy: Managing personal information in line with the entity’s privacy notice, including collection, use, retention, disclosure, and disposal.

The relevance and implementation of these criteria depend on the services your organization offers and the commitments it has made.

Types of SOC 2 Reports: Type I vs. Type II

SOC 2 reports fall into two categories:

  • Type I: Evaluates the design of controls at a specific point in time.

  • Type II: Assesses the operational effectiveness of controls over a period, typically 3 to 12 months.

Type I is ideal for organizations undergoing their first SOC 2 assessment, while Type II offers a more comprehensive review of control performance over time.

5 COSO components and the 17 COSO Principles

The COSO framework underpins SOC 2’s internal control system, comprising five components and 13 principles:

  • Control Environment: Establishes integrity, ethics, and governance.

  • Risk Assessment: Identifies and evaluates risks to achieving objectives.

  • Control Activities: Implements policies and procedures to mitigate risks.

  • Information and Communication: Ensures the flow of relevant, timely information.

  • Monitoring Activities: Regularly assesses the performance of internal controls.

These components help build a robust and effective internal control environment.

Understand the scope and objectives of your business

Before applying SOC 2 controls, define your organization’s scope and objectives:

  • Identify Services: Clarify which systems and services handle customer data.

  • Set Objectives: Determine your compliance goals, such as enhancing data security or meeting client requirements.

A clear understanding of your scope and objectives allows you to tailor SOC 2 controls effectively.

Risk Identification and Analysis

A comprehensive risk assessment highlights areas that pose potential threats to data security:

  • Asset Identification: Catalog all assets that store or process sensitive data.

  • Threat Analysis: Evaluate both internal and external risks.

  • Risk Assessment: Estimate the likelihood and impact of each risk.

These insights are critical in designing effective and targeted security controls.

Developing Policies and Procedures

Strong policies and procedures form the backbone of SOC 2 compliance:

  • Security Policies: Define access control, data handling, and incident response guidelines.

  • Operational Procedures: Outline change management, backup protocols, and system operations.

Review and update these documents regularly to reflect changes in operations or regulations.

Training and Awareness

Employee training and awareness ensure policies are consistently applied:

  • Regular Training: Provide ongoing training on data security best practices.

  • Awareness Programs: Encourage a culture of security throughout the organization.

A knowledgeable team is your first line of defense against potential breaches.

Mandatory Security Criteria

Among the five Trust Services Criteria, Security is the only mandatory criterion for all SOC 2 assessments. The applicability of the remaining four, Availability, Processing Integrity, Confidentiality, and Privacy, depends on the nature of your services and customer commitments.

For example:

  • If you offer a SaaS platform that stores customer data, Confidentiality becomes relevant.

  • If your customers rely on the uptime of your services, Availability applies.

  • If you process data on behalf of clients and the accuracy or timeliness of that processing is critical, Processing Integrity is applicable.

  • If you handle end-user personal information, Privacy must also be addressed.

In short, these criteria aren’t optional, they’re conditionally applicable based on your business model and the expectations of your stakeholders.

The Security TSC contains 9 sections, the first 5 of which are the same as COSO components discussed earlier. We will walk through each of them.

These include:

Control Environment:

The control environment sets the tone of the organization and forms the foundation for all other components of internal control. It includes the following principles:

1. Demonstrates Commitment to Integrity and Ethical Values:

The organization establishes and maintains standards of conduct and demonstrates a culture of integrity and ethics in decision-making and behavior.

2. Exercises Oversight Responsibility:

The board of directors and/or those charged with governance provide independent oversight of the development and performance of internal control.

3. Establishes Structure, Authority, and Responsibility:

The organization defines clear reporting lines, responsibilities, and authorities to support the effective design and implementation of controls.

4. Demonstrates Commitment to Competence:

The organization attracts, develops, and retains competent individuals to fulfill its operational and compliance responsibilities.

5. Enforces Accountability:

Accountability is established through performance evaluation, disciplinary measures, and reward systems that align with the organization’s objectives and control expectations.

This structured foundation influences how control activities are designed, implemented, and maintained across the organization.

Information and Communication

This COSO component ensures that information flows efficiently within and outside the organization. It consists of the following principles:

  • Obtaining and Using Relevant Information: The organization identifies and gathers quality information to support the functioning of internal controls, including identifying and classifying assets and data flows.

  • Internal Communication: Security-related responsibilities, incidents, and updates are communicated clearly within the organization. Training and awareness programs support these objectives.

  • External Communication: Communicates relevant security objectives, controls, and updates to external stakeholders, vendors, and clients using secure and timely channels.

Risk Assessment

Risk assessment is critical to identifying and managing potential threats to system security. The principles are:

  • Specifying Objectives: Clearly defines system security objectives to guide risk identification and evaluation.

  • Identifying and Analyzing Risks: Considers internal and external threats, including vendor and partner risks.

  • Assessing Fraud Risk: Evaluates the potential for internal or external fraud impacting data and systems.

  • Identifying and Analyzing Significant Change: Assesses risks resulting from changes in systems, leadership, vendors, or regulatory environments.

Monitoring Activities

Monitoring ensures controls are present and function as intended:

  • Ongoing and Separate Evaluations: Uses a mix of regular and periodic evaluations to review control performance, including vulnerability scans, penetration testing, and internal audits.

  • Evaluation and Communication of Deficiencies: Ensures timely identification and communication of control failures to responsible personnel, along with follow-up actions.

Control Activities

These are actions that mitigate risks and enforce policies:

  • Control Activities for Risk Response: Develops controls to reduce risk to acceptable levels, including both manual and automated processes.

  • General IT Controls: Applies controls over technology infrastructure, access, and system development.

  • Deployment Through Policies and Procedures: Communicates expected behaviors and responsibilities through documented policies and ensures consistent execution.

Logical and Physical Access Controls

Effective access controls are key to protecting sensitive data. This section of the Security criteria outlines how logical and physical access to systems and data should be restricted, monitored, and managed to meet organisational objectives.

1. Logical Access Security Implementation

Implement logical access controls using security software, infrastructure, and architecture to protect information assets. This includes the use of access control software, configuration standards, and authentication rule sets.

2. User Identification and Authentication

Identify and authenticate users (including people, systems, and software) before granting access to information assets. Use multi-factor authentication where appropriate, based on risk.

3. Access Credential Management

Create and manage access credentials (usernames, passwords, certificates) based on authorisation from asset owners. Revoke credentials when access is no longer required.

4. Role-Based Access and Least Privilege

Authorise access based on user roles and responsibilities, enforcing the principle of least privilege and ensuring segregation of duties through access control structures.

5. Physical Access Restrictions

Restrict physical access to data centres, servers, and protected areas to authorised personnel. Secure facilities with access badges, locks, and surveillance systems.

6. Credential Revocation and Physical Asset Recovery

Revoke access and retrieve physical assets (such as laptops, access cards, and mobile devices) when personnel exit the organisation or no longer require access.

7. Periodic Access Reviews

Review logical and physical access permissions periodically to ensure they remain appropriate for each user’s responsibilities and status.

8. Encryption and Cryptographic Key Management

Use encryption to protect data at rest, in transit, and during processing. Implement robust cryptographic key generation, storage, usage, and destruction practices aligned with the organisation’s risk mitigation strategy.

Regular audits and monitoring of these controls are essential to ensure they function properly and adapt to emerging threats.

System Operations (5 requirements)

Secure system operations depend on proactive monitoring, detection, and corrective mechanisms. These criteria ensure that systems operate reliably and securely in alignment with business objectives.

1. Monitoring of System Components

Continuously monitor system components to detect deviations in security, availability, and performance. Monitoring tools and procedures must provide timely alerts for anomalies, unauthorised access, or operational failures.

2. Detection and Response to Deviations

Establish mechanisms to detect processing deviations, configuration changes, or errors in real-time. Systems must be capable of logging and reporting deviations so that corrective actions can be taken promptly.

3. Incident Management

Maintain documented processes for identifying, reporting, investigating, and responding to operational incidents. This includes assigning responsibilities and ensuring the timely escalation of critical issues.

4. System Maintenance and Updates

Apply regular system maintenance, including the deployment of security patches and updates. Organisations must follow a change-controlled approach to ensure updates do not introduce new vulnerabilities.

5. Backup and Recovery Procedures

Implement reliable backup and recovery processes that safeguard data and system configurations. These processes should support restoration in the event of hardware failure, cyberattacks, or other disruptions.

These practices collectively ensure the ongoing integrity, availability, and resilience of systems, allowing organizations to meet service commitments and operational expectations.

Change Management

A structured change management process reduces operational risks:

  • Change Requests: Document and approve changes before implementation to ensure seamless integration.

  • Testing: Test changes in staging environments to uncover issues early.

  • Review: Conduct post-implementation reviews to evaluate outcomes.

This systematic approach helps prevent disruptions and maintains consistency in control.

Risk Mitigation

Implement controls aligned with your risk assessment to protect against data threats:

  • Preventive Controls: Deploy firewalls, encryption, and antivirus tools to stop incidents before they happen.

  • Detective Controls: Use intrusion detection systems and monitoring tools to identify issues.

  • Corrective Controls: Define clear protocols for responding to and recovering from security incidents.

Regularly reviewing and updating these controls keeps them aligned with emerging threats.

Evidence Collection and Audit Readiness

Preparing for a SOC 2 audit means gathering verifiable proof of control effectiveness:

  • Documentation: Maintain up-to-date records of procedures, policies, and control measures.

  • Logs and Reports: Collect relevant system activity logs and monitoring data.

  • Audit Trails: Ensure traceability of key actions and system changes.

A standardized evidence collection process simplifies audits and reduces errors.

Attestation - Who can Audit, Selecting an Auditor

SOC 2 audits must be conducted by independent Certified Public Accountants (CPAs) or licensed SOC examiners. When choosing an auditor:

  • Experience: Select one with expertise in your industry.

  • Reputation: Look for proven credibility and positive client reviews.

  • Method: Confirm their audit process aligns with your organizational needs.

The right auditor can streamline your journey toward compliance.

SOC 2 Maintenance and Compliance

SOC 2 compliance is an ongoing commitment, not a one-time activity:

  • Continuous Monitoring: Regularly monitor systems and controls for changes or breaches.

  • Periodic Reviews: Update policies and procedures as necessary.

  • Employee Training: Provide continuous training and refreshers.

  • Internal Audits: Conduct internal assessments to catch issues early.

  • Monitor Changes: Track and document system/process changes that affect controls.

  • Third-party Providers: Ensure vendors meet your security standards.

  • Policy Revisions: Update policies in response to new threats or regulatory changes.

SOC 2 Type II reports must be renewed annually. Maintaining audit readiness year-round prevents last-minute issues and ensures consistent compliance.

Tips for Smooth SOC 2 Implementation

SOC 2 implementation can feel daunting, especially for smaller or scaling teams. Here are some actionable tips:

  • Start Early: SOC 2 Type II requires 3–12 months of monitoring. Begin preparations well in advance.

  • Focus on the Basics: Start with the mandatory security criteria before expanding scope.

  • Document Everything: Detailed records are crucial for audit success.

  • Involve Stakeholders: Bring in IT, HR, and legal early. SOC 2 is a collaborative effort.

  • Select the Right Auditor: Choose one who acts as a guide, not just an evaluator.

Conclusion

SOC 2 compliance is essential for any organization managing customer data. It fosters client trust, reduces security risks, and reflects your commitment to data protection. By defining your business scope, leveraging the COSO framework, implementing effective controls, and staying audit-ready, you can ensure long-term resilience and credibility.

Start small, stay consistent, and embed a security-first mindset into your culture. SOC 2 isn’t just an audit, it’s a framework for building a safer, more trusted business.