SOC 2 Controls and How To Implement Them

What Are SOC 2 Controls?

SOC 2 controls are internal policies that protect systems and data from unauthorized access, disclosure, and use, as required by the SOC 2 framework. Some examples include access controls, data encryption controls, and risk assessment controls.

The number and type of SOC 2 controls depend on the organization and the Trust Services Criteria (TSC) selected for compliance. This means there aren’t any universal SOC 2 requirements for audits.  

During an audit, a certified public accountant (CPA) evaluates your service organization’s controls. Controls are evaluated against the chosen TSC to create a SOC 2 audit report. This helps you show stakeholders that you can protect their data and remain compliant with SOC 2 standards. 

SOC 2 Controls List

The American Institute of Certified Public Accountants (AICPA) outlines nine criteria as the foundation for SOC 2 compliance. These criteria act as the main control requirements for the framework. 

The first five apply to all TSCs and ensure baseline compliance. The remaining four, known as the supplemental criteria, apply only to the Availability, Confidentiality, Processing Integrity, and Privacy TSCs. 

The number and type of controls you’ll need depend on the TSC your organization selects for compliance. Let’s look through all of them:  

1. Control Environment   These controls include CC1.1 to CC1.5 and require companies to set up a strong foundation for compliance through leadership and organizational policies.  This means organizations must define ethical standards related to data use, create a code of conduct, and ensure accountability across all levels of the organization. 2. Communication and Information Communication and information controls are outlined in CC2.1 to CC2.3. They focus on how an organization communicates essential information internally and externally to support compliance with SOC 2 requirements.  These controls ensure that relevant data reaches the right people at the right time and allow for informed decision-making.  3. Risk Assessment Controls Risk assessment controls include CC3.1 to CC3.4. They focus on identifying, analyzing, and responding to risks that could impact an organization’s ability to meet its SOC 2 objectives.   They require service organizations to understand risks to systems, data, and operations. This understanding is gained by focusing on internal factors like processes and external factors like cybersecurity threats.

4. Monitoring Activities  

Monitoring activities controls are outlined in CC4.1 to CC4.2. These controls ensure that an organization’s systems and processes remain effective over time. They require companies to: 

• Continuously track system performance
• Verify policies and procedures
• Identify potential risks
• Communicate them to relevant teams
• Address weaknesses before they impact operations 

5. Controls Activities 

The controls include CC5.1 to CC5.3. They require an organization to select and develop activities that reduce the risks that prevent it from reaching its goals. Examples include:

• Access restrictions to sensitive data
• Using multi-factor authentication (MFA) for restricted systems
• Managerial approval for system changes

While these controls seem similar to CC7 controls, they’re preventative measures designed to stop issues before they occur. CC7 controls, however, focus on monitoring and responding to operational issues that come up during system use. 

6. Logical and Physical Access Controls

Logical and physical access controls, outlined in CC6.1 to CC6.9, ensure only authorized individuals interact with critical resources, reducing security risks and maintaining operational integrity.

Logical controls address digital security, such as role-based access, user credentialing, and data or software access authorization. Physical controls safeguard tangible assets like servers and data centers, using measures such as key cards, biometrics, surveillance cameras, and visitor management.

7. System Operations Controls

System operations controls, outlined in CC7.1 to CC7.5, ensure reliable system performance, prevent disruptions, and maintain data integrity.

Examples include detection and monitoring procedures to identify unauthorized configuration changes that could introduce vulnerabilities. These controls also support data recovery through backups, incident response, and system checks.

8. Change Management Controls 

Change management controls consist of CC8.1. This includes controls related to approvals, authorization, design, development, implementation, and testing. 

These controls ensure that modifications to software, systems, data, or infrastructure are properly reviewed and approved before implementation. They also focus on aligning changes with the company’s objectives and do not introduce unnecessary risks or disruptions. 

9. Risk Mitigation Controls 

Risk mitigation (CC9.1–CC9.2) reduces vulnerabilities and limits incident impact, focusing on risks in external collaborations and shared environments, unlike CC3 and CC5.

CC9.2 emphasizes managing risks in shared operations with business partners to ensure smooth transactions. Risk assessments underpin CC9 controls by identifying potential exposures, such as outdated software or unpatched systems, enabling targeted remediation. 

Examples of SOC 2 Compliance Controls 

The TSC has five categories and 64 individual requirements. Each TSC requires specific controls to address its focus areas. Let’s understand what the requirements look like for each criterion:  

SOC 2 Controls for Security 

Security is the foundation of SOC 2 compliance. Your customers and stakeholders want to know what measures you’ve taken—whether physical or software-related—to protect their data.

This is why controls in this category focus on protecting your systems and data from unauthorized access, misuse, and potential threats. They include: 

• Access controls—These ensure that only authorized personnel can access systems and data
• System monitoring—It helps detect and respond to unauthorized activity through alerts and automated monitoring tools 
• Incident response plans—These contain procedures to detect, address, and recover from security incidents 

Security controls also include physical security measures like restricted access to data centers, surveillance systems, and visitor logging. 

SOC 2 Controls for Availability  

Availability controls ensure that your systems and services remain accessible to users as promised. They focus on maintaining system uptime, reducing downtime, increasing performance, and improving your company’s ability to recover quickly from disruptions.  

Service organizations have to adhere to the A1 series’ requirements to become SOC 2 compliant. Here’s how they can do that: 

• Capacity planning—This helps organizations monitor current system capacity, forecast future demand, and scale resources to prevent capacity-related outages
• Regular backups—They make sure data and services can be restored after disruptions
• System redundancy—This includes failover systems and redundant infrastructure to reduce downtime  

Other measures include environmental protections and regular incident response testing, which help organizations recover systems quickly. 

SOC 2 Controls for Processing Integrity 

Processing integrity controls focus on ensuring that system operations are complete, accurate, and free from unauthorized manipulation. 

These controls assure your clients that your systems provide accurate and dependable results as promised. They include: 

• Input validation processes—This ensures that data entered into systems is complete, accurate, and within acceptable parameters
• System operations monitoring—This helps flag incomplete or inconsistent data for review
• Change control reviews—This verifies that all changes to processes, software, or infrastructure are authorized, tested, and implemented properly

SOC 2 Controls for Confidentiality 

Confidentiality controls protect sensitive information from unauthorized access, use, or disclosure. 

They ensure that any data classified as confidential—such as proprietary business information, customer details, or trade secrets—is securely managed in line with client expectations and regulatory requirements.

To meet the confidentiality requirements of SOC 2, organizations have to implement controls like CC6, CC7, and C1.1 to C1.2. These require them to: 

• Restrict access to confidential data based on roles and responsibilities. This ensures that only authorized personnel can view or handle sensitive information.
• Use encryption protocols to protect data during transmission and while stored.
• Track access to confidential data and review logs for unauthorized activity or potential security breaches.

SOC 2 Controls for Privacy 

SOC 2 controls for privacy focus on how service organizations handle personal information. They protect the collection, use, retention, disclosure, and disposal of personal information. Here’s what they include: 

• Notice and consent management—This notifies individuals about how their personal information will be used
• Data retention policies—These define how long personal information is retained and disposed of
• Privacy breach notifications—These are established procedures for notifying people and authorities in case of a data breach

How Long Does It Take To Implement SOC 2 Controls?

How long it takes for you to implement SOC 2 controls depends on two factors:

• Your organization’s baseline status. If your internal practices are already in accordance with SOC 2 guidelines, it will take you shorter to implement SOC 2 controls
• The expertise you have available. If you have a large internal team with SOC 2 expertise, you’ll be able to implement SOC 2 controls quickly. If not, you’ll have to spend more time on them (unless you hire external help)

How To Implement SOC 2 Controls?

Implementing SOC 2 controls is mainly about studying internal practices, comparing them to SOC 2 guidelines, and closing the gap. Here is what the process looks like:

1. Identify Your SOC 2 Scope

The first step is to understand your SOC 2 scope, which includes the areas of internal controls an auditor will access during your audit. This includes the systems, processes, TSCs, and SOC 2 report types that apply to your organization. 

You can either work with an auditor to figure this out or go over your customer contracts, regulatory requirements, and internal objectives to understand what applies. 

2. Perform a Gap Analysis 

Once you know your SOC 2 scope, you need to perform a gap analysis to figure out where your current practices fall short of SOC 2 requirements. 

Here are some questions to ask: 

• Do you already have access controls in place? 
• Are your monitoring systems and tools up to par? 
• Can you show how your organization handles incidents or maintains data integrity? 
• Do you have documentation of your controls? 
• Are there any written policies that outline how sensitive data is stored or how employees are trained to follow security protocols? 

You’ll need to perform a detailed review of your systems, policies, and procedures to understand how they work. This can take a lot of time, especially if you don’t know where to start. 

3. Close Gaps 

Your gap analysis report is going to be a big help here because it’ll list exactly what to fix, what’s critical, and when to fix it. 

Here’s what you’ll usually do at this point: 

• Prioritize your gaps based on their risk level and impact. High-risk areas—such as a lack of multi-factor authentication—should always take precedence over lower-risk ones.
• Establish the necessary policies, procedures, and tools to improve your security posture.
• Document everything you’re doing to show that you’re complying with SOC 2 TSCs.
• Test that your new implementation works as intended and fix what doesn’t work.
• Train your team on your new data-handling practices.

4. Conduct a Readiness Assessment

It’s time to test how well your controls meet relevant SOC 2 criteria. You can do this through a readiness assessment. This requires you to review your policies, procedures, and systems to confirm that they align with SOC 2 requirements. 

To make sure this process is thorough, The Pun Group can conduct this assessment for you. Our CPAs will evaluate your existing controls to establish a baseline for your internal controls. This helps identify any gaps or areas that don’t fully meet the criteria. 

After that, we’ll work with your team to develop remediation strategies that close gaps and make sure they remain closed over time. 

5. Undergo the SOC 2 Audit

With your readiness assessment complete, it’s time to undergo the SOC 2 audit. This is where an independent auditor will evaluate your organization to ensure compliance with the TSCs.

During the audit, the auditor will assess your systems, policies, and procedures based on the type of report you’ve chosen. 

Everyone who’s going to be involved in the audit needs to understand their roles and be ready to explain what they’re doing. This can help you show your commitment to compliance with SOC 2. 

Ensure SOC 2 Controls Compliance With The Pun Group

SOC 2 compliance requires you to align your controls with the TSC, close gaps, and make sure your systems and processes protect sensitive data against unauthorized access, breaches, and operational risks. 

It can have many moving parts, each changing the more changes you make. Following through with every requirement can quickly become difficult. That’s where we come in. 

At The Pun Group, we know that aligning with SOC 2 requirements is complex, vague, and time-consuming. This is especially true when the criteria seem open to interpretation or when every adjustment to your systems creates new problems. 

This is why we walk you through every step of the process. Our team helps you figure out the right TSCs for your business, close compliance gaps, and implement controls that meet SOC 2 standards and your business goals. 

If you’re ready to reassure your clients that their information is in safe hands, we’ll support you every step of the way.

Reach out to us today!