How to Maintain SOC 2 Compliance

How to Maintain SOC 2 Compliance?

Maintaining SOC 2 compliance requires ongoing effort. You need to continuously monitor your systems, conduct regular risk assessments, and update security controls whenever necessary.

The purpose of SOC 2 compliance is to show your potential customers and stakeholders that they can trust you to keep sensitive customer data safe. 

Since the compliance audit process is performed by an independent Certified Public Accountant, it provides external validation of your new business’s trustworthiness. Having strong security policies and controls is great, but a SOC 2 report takes it further by having an outside expert confirm your business is truly secure.

Here’s a closer look at the steps involved in maintaining it:

Continuous Monitoring

In the context of SOC 2, continuous monitoring refers to regularly assessing an organization’s systems and security controls to ensure they align with the SOC 2 framework. This ongoing process helps maintain a continuous compliance program and identifies potential issues before they escalate.

Monitoring activities are a core part of the SOC 2 Trust Services Criteria, particularly security and common criteria under SOC 2 Type 1 or Type 2. These activities are rooted in the COSO framework for internal control, which is widely recognized for its best governance and risk management processes.

Here’s how COSO outlines monitoring principles:

1. Principle 16: Organizations must choose, develop, and carry out ongoing or periodic evaluations to confirm that internal control components are in place and functioning effectively.
2. Principle 17: Organizations should assess and communicate any internal control deficiencies promptly to those responsible for addressing them, including senior management and the board of directors, when necessary.

To simplify continuous monitoring, you can leverage third-party tools or CPA firm that automate and streamline the compliance process like audit readiness, incident response plan and evidence collection making it easier to stay on top of compliance requirements.

Conduct Regular Risk Assessment

In SOC 2 risk assessment is an important regulatory requirements. It starts with identifying, selecting, and developing strategies to mitigate identified risks, especially those tied to potential business disruptions.

Here are key actionable steps for conducting a SOC 2 risk assessment in line with trust service principles:

• Define Organizational Objectives. Clearly document your strategic, operational, and financial goals.
• Identify Potential Risks. Assess risks across IT, system operations, and external factors.
• Evaluate Risks. Use a structured method (e.g., Likelihood x Impact) to prioritize risks.
• Establish Risk Mitigation Strategies. Develop action plans for managing or mitigating high-priority risks.
• Consider Fraud Risks. Analyze potential fraud risks in processes and systems.
• Assess Vendor Risks. Review third-party vendors for data security and compliance risks.
• Monitor for Business Disruptions. Identify risks from disruptions like technology failures or natural disasters.
• Review Changes in Technology. Assess how new or changing technologies could impact risks.
• Document and Communicate Findings. Record risk assessment results and share them with stakeholders.
• Implement Ongoing Risk Monitoring. Continuously monitor risks and adjust strategies as needed.

Note: The SOC 2 compliance framework contains seven key criteria that relate directly to your organization’s risk assessment and management processes. 

Now, let’s deep dive into the risk assessment requirements mentioned in the SOC 2 common criteria:

• CC3.1. Define clear objectives to identify and assess risks.
• CC3.2. Identify and analyze risks to determine management strategies.
• CC3.3. Address fraud risks, considering factors like motive, opportunity, and rationalization.
• CC3.4. Assess organizational changes (e.g., technology, leadership, regulations) to implement controls.

• CC5.1. Develop controls to reduce risks to acceptable levels.
• CC5.2. Implement technology-focused controls to achieve objectives.
• CC9.1. highlights risk mitigation for business disruptions, emphasizing policies, alternative processing sites, communication during recovery efforts, cybersecurity insurance, and business continuity planning.

Be Up-To-Date With Policy and Procedure Documentation

SOC 2 documentation is your organization’s commitment to doing things the right way. It shows proof that your organization has implemented the necessary policies, procedures, and control activities to meet the TSC in a structured and effective way.

Here’s a list of documents typically required for SOC 2 compliance:

• Information Security Policies
• Risk Assessment Reports
• System and Network Configuration Documentation
• Employee Training Records
• Incident Management Logs
• Vendor Risk Management Documents
• Change Management Records
• Monitoring and Audit Logs
• Business Continuity and Disaster Recovery Plans
• Access Control Documents

Here are the steps you need to take to align with policy and procedure documentation:

• Review Regularly. Update policies and procedures to reflect any changes in processes or regulations.
• Document the Effectiveness of Controls. Ensure all internal controls related to security, availability, processing integrity, confidentiality, and privacy are clearly documented.
• Align with TSC. Make sure your documentation covers all five trust principles.
• Involve Stakeholders. Get input from relevant teams (e.g., IT, HR, security) to ensure thoroughness.
• Keep Records Accessible. Store your documentation in an easily accessible place for audits and internal reviews.
• Track Changes. Keep a log of revisions to ensure transparency and easy reference during audits.

Implement Access Controls

SOC 2 access controls are key security measures to manage and limit unauthorized access and who can access your company’s systems and confidential information. The main goal is to make sure unauthorized individuals can’t get their hands on sensitive information.

A great example of a SOC 2 Type II control is role-based access control (RBAC). With RBAC, you assign specific roles to users within the organization and give them access to only the resources they need to do their job. 

Here’s how to do it: 

• Define User Roles. Identify and define roles within your organization based on job functions.
• Set Access Permissions. Assign access rights to each role based on the resources needed for their tasks.
• Use Role-Based Access Control (RBAC). Implement RBAC to ensure users only access the systems and data relevant to their role.
• Review Access Regularly. Regularly assess the scope of your audit and update access permissions to ensure they remain aligned with job functions.
• Enforce Strong Authentication. Mandate MFA for added security when accessing sensitive data or systems.
• Monitor Access Logs. Keep track of who is accessing what, when, and why to spot any suspicious activity.
• Revoking Access. Revoke access for users who no longer need it, such as when they change roles or leave the company as part of security requirements.

Employee Training

Employees make or break business. Proper training is critical to ensure they understand their role in protecting sensitive information from data breaches.

Nearly half of businesses experienced a ransomware attack in the past year, and 46% were hit more than once. These numbers highlight just how essential it is to equip your team with the knowledge to recognize and respond to potential threats and safeguard customers’ data.

Here are the steps you need to take:

• Identify Training Needs. Assess security-related knowledge gaps among employees based on their roles and responsibilities.
• Develop Tailored Training Programs. Create training materials focusing on SOC 2 principles, including data protection, access controls, and incident response.
• Conduct Regular Training Sessions. Schedule frequent sessions to ensure employees stay updated on evolving security practices.
• Simulate Real-World Scenarios: Use phishing simulations or mock security incidents to teach employees how to respond effectively.
• Provide Role-Specific Training. Offer specialized training for teams handling sensitive data or managing critical systems for a stronger compliance posture.

How Can The Pun Group Help You Maintain SOC 2 Compliance?

Maintaining SOC 2 compliance requires ongoing commitment. While the audit report itself may take up to 12 months to complete and remains valid for another 12 months, maintaining compliance requires continuous effort. 

You can’t afford to pause once the SOC report is done for your cloud services; instead, you need to build a consistent standard that your organization regularly audits and improves.

This process can be overwhelming to handle alone, which is where The Pun Group comes in. With our experience as the finalists for the AICPA Innovative Practitioner Award and access to Allinial Global’s network of independent accounting firms, we provide the expertise and resources to simplify your SOC 2 Type II report for competitive advantage.

Ready to make compliance seamless? Schedule a call with us today.