How to Achieve SOC 2 Compliance

A prior article discussed how System and Organization Controls (SOC) 2 reports—a framework developed by the American Institute of Certified Public Accountants (AICPA)—offer a competitive advantage to service organizations. This article addresses how to achieve SOC 2 compliance, how to face common challenges in attaining SOC 2 compliance and best practices for maintaining it.

Steps to Achieve Compliance with SOC 2

Attaining SOC 2 compliance is a structured process that involves preparation, remediation and auditing. These steps generally include the following:

Step 1 – Define the Scope: Determine the services and systems for coverage. It’s not uncommon for organizations to have more than one SOC report over various systems and services. Further, determine which AICPA Trust Service Criteria (TSC) will be included in the audit based on the organization’s services, client requirements and risk factors.

Step 2 – Perform a Readiness Assessment: Identify key controls that mitigate risks and align to the applicable TSC. This will provide organizations an opportunity to identify weaknesses in controls and gaps in coverage so a remediation plan can be developed.  

Step 3 – Implement Controls: Based on the identified gaps and weaknesses in the readiness assessment, implement or update controls to meet the criteria. This may involve security measures, employee training and process documentation.

Step 4 – Pre-Audit Assessment: Conduct a review to ensure all controls are properly implemented and functioning as intended before the official audit.

Step 5 – Undergo Audit: Organizations can elect to undergo either a Type I or II audit. Most organizations begin with the Type I audit before moving to Type II in subsequent reporting periods. The audit must be conducted by a Certified Public Accountant with the necessary experience.

Step 6 – Address Findings: Remediate any deficiencies found during the audit. The goal is to encourage continual improvement to mitigate emerging risks by maintaining the effectiveness of controls. Obtaining a successful SOC 2 report doesn’t mean the journey ends there. 

Step 7 – Ongoing Monitoring and Reassessment: SOC 2 is not a one-time event; organizations should continuously monitor and update controls to ensure ongoing compliance.

Challenges in Achieving SOC 2 Compliance

Knowing the common challenges organizations face in attaining SOC 2 compliance can better prepare companies to avoid them. Common challenges include:

• Failure to accurately define the scope of services and systems at the outset of a SOC 2 audit can lead to wasted resources and an ineffective audit process.
• Additionally, organizations must carefully consider their service commitments to identify the relevant TSC. Neglecting to include a relevant criterion can reduce the final report’s utility for customers. For instance, if an organization commits to maintaining confidentiality for its customers but omits the confidentiality TSC from the report, it may raise questions and concerns among stakeholders.
• Achieving SOC 2 compliance requires a strong organizational commitment. Without clear communication and buy-in from top management, the process may run into unnecessary hurdles or delays.
• Further, the SOC 2 process is time-intensive, often taking several months to complete. Organizations must plan adequately and allocate sufficient time to meet their compliance goals. This is especially important if SOC 2 is required to fulfill contractual obligations. Proper scheduling and resource allocation can prevent last-minute setbacks and ensure a smoother audit process.
• And lastly, as cyber threats become more sophisticated, maintaining up-to-date controls becomes more resource intensive. Leadership should assign ownership of the security program to ensure continuous updates and improvements.

Despite these challenges, the benefits of SOC 2 compliance—improved security posture, enhanced customer trust and competitive differentiation—often outweigh the setbacks.

Best Practices

As organizations go through the SOC 2 compliance process, a few important best practices are outlined below:

Communication and Ownership: Controls owners should be aware of the responsibility to uphold their practices. Ensuring effective communication about these responsibilities can keep controls operating effectively. It’s recommended to conduct ongoing training that reiterates staff’s role in maintaining data security and compliance.

Risk Assessment Procedure: Establishing a mature and effective risk assessment process can help identify new or emerging risks that require treatment.

Regularly Review and Update Controls: As business processes and technologies change, controls may need to be updated to remain effective.

Conduct Periodic Internal Audits: Regular self-assessments can help ensure that controls are functioning as intended between official SOC 2 audits.

Next Steps

When handling sensitive customer data, a SOC 2 report can boost client confidence and an organization’s reputation. Performing this audit demonstrates a commitment to data security, and it provides assurance to customers that their information is being handled in a trustworthy manner. By understanding the requirements, preparing thoroughly and maintaining ongoing compliance practices, companies can achieve SOC 2 certification.

If you think that SOC 2 could enhance your organization’s data security, customer trust and business growth, contact the Sikich team today.