Cybersecurity is a major concern in today's world, and a System and Organization Controls (SOC) 2 report helps demonstrate your organization's commitment to data security. Even if your organization has a robust cybersecurity framework already in place, undergoing a SOC 2 evaluation may identify gaps in your information security controls, as well as provide clues on how to mitigate potential risks. The SOC 2 report is an assurance service that evaluates how your information security controls align and ensure achievement of AICPA trust service criteria. Taking this step allows your organization to meet the highest standards of data security, ensuring internal and external stakeholders that their valuable information is in safe hands.
The first time you undergo a SOC 2 report, there may be some challenges, so it's important to know what to expect.
Seeing the Whole Picture
First-timers to the SOC 2 process often engage in a path of increasingly robust evaluations that include: SOC readiness, a SOC 2 Type 1, which is a point-in-time review of controls that entails an evaluation of the design of your controls, and a SOC 2 Type 2, which assesses the operating effectiveness of your controls over time. Each phase involves comparison and analysis between what your organization has in place and the standards set by the AICPA SOC 2 framework.
But before getting started with the SOC 2 readiness, it may be helpful to evaluate some important steps that can be taken before you formally commence with your SOC 2 report. Without the following in place, your organization may face a more challenging SOC 2 process.
A Current Risk Assessment
Your organization likely addresses risk daily, but are those assessments and results written down?
Many companies fail to document considerations and evaluations of cybersecurity risk as they occur throughout the year, forcing employees to rush to haphazardly inventory their risks before undergoing a SOC 2 engagement. That could lead to missed areas of exposure and a risk assessment that really misses out on its intended purpose of guiding an organization in its risk management strategy.
Regularly mapping out each risk in detail, along with mitigating risk activities, allows your organization to maintain a comprehensive and accurate risk assessment that will be valuable during a SOC 2 evaluation. It's also essential to thoroughly re-evaluate your organization's "risk universe," encompassing all significant risks that may affect your business.
Considering 3P Risk Assessments
When evaluating your cybersecurity, it's essential to understand the interconnectedness of your organization and the potential risks posed by your business partners. One way to mitigate those risks is through performing risk assessments on your business partners and requesting information about their controls. It's also important to have a process in place to respond if a breach occurs at one of your partner organizations.
These third-party (3P) risk assessments can take many shapes and forms, and organizations often find themselves in the business of over-documenting or under-documenting these evaluations. Many organizations trip up right at the onset of a 3P risk assessment by failing to identify the subservice providers that they should evaluate sufficiently as part of their enterprise information security program. Your organization should also determine what vendors it needs to evaluate, how often, and what the review shall entail (e.g. reviews of your vendors’ SOC 2 reports).
Creating Formalized Policies
Another area that first time SOC organizations struggle with is ensuring that they have formal policies written related to their organization's cybersecurity controls. To ensure you have a successful SOC 2 report, you must have all your policies and controls in writing and up-to-date to show auditors you have a comprehensive cybersecurity framework in place.
When you document your policies, you should define the purpose of the policy and its intended audience. In addition, it is best practice to record any revisions of the policy, so you're aware of what policies were in place at any given time. Engaging stakeholders across departments to provide input and offer feedback is another way to ensure due diligence. Once formalized, your policies should also be approved by a senior leader within the organization who represents the appropriate critical area of your organization.
Upon completion, keep your policies in an easily accessible location so employees can reference them when needed to ensure they are following organizational procedures on the job. Be sure that employees have read and understood the policies through interdepartmental communication or training sessions. And ultimately, the upkeep of those policies is vital. Review each of them annually and update them as needed.
Preparing Control Documentation for Review
Organized documentation goes a long way toward making your SOC 2 evaluation more streamlined. Too often, organizations rely on email or PDFs for documenting approvals of core control activities but then lack vision on how to make those documents easily accessible during an evaluation. Spending time with implementing document management protocol will be key to a successful engagement.
With some preparation and planning ahead of time, the SOC 2 process can be much less daunting than it seems on paper. Remember that the key is not only knowing what needs to be done as part of the SOC 2, but also how those tasks must happen. If you require help with any part of your organization's security framework or have questions about other aspects of a SOC report, please contact us.
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Published on January 18, 2022