SOC 2 compliance is stressful for many organizations, but achieving continuous compliance while lowering the annual frustration is within your reach. This article, which originally appeared on the ISACA blog, breaks down four steps that lead to continuous SOC 2 compliance.
Steps to SOC 2 Continuous Compliance
Step 1: Identify Your Scope
The first step on the way to SOC 2 compliance is scoping. AICPA established the five core Trust Services Criteria that a SOC 2 audit should consider. These criteria are based on the systems and processes in place at the organization — not every SOC 2 audit must consider all five categories. Then, determine which systems, policies, and procedures support relevant principles. Additional scoping considerations include your system(s) in-scope (i.e. applications or services, people, locations or entities, technology) and the timeline for the overall project from initiation to having the SOC 2 report readily available.
Step 2: Gap Analysis & Control Mapping
Perform a readiness assessment of the control environment to identify gaps between the Trust Services Criteria and the internal control environment. This will determine if your existing controls are enough to meet the SOC 2 auditor’s expectations. Performing a gap analysis or readiness assessment before the audit can help you close any lingering gaps in your compliance, enabling a more efficient audit process.
Once you’ve gathered your controls, map your control environment to the Trust Services Criteria — and also start gathering applicable documentation such as policies and procedures. Deliberately mapping the controls creates evidence of a complete and well-designed control structure. The mapping also provides the foundation management needs so they can attest to having controls in place to meet the SOC 2 criteria.
Step 3: External Reporting
Finding a good partner for the SOC 2 audit is essential. Only a CPA firm can conduct your SOC 2 audit — but that doesn’t mean that every CPA firm is a good fit for your SOC 2 audit. Find a CPA that understands the specific needs of your industry and organization. Build a relationship with the external auditors who will perform their own independent testing and provide an opinion on whether or not they agree with management’s assertion — ultimately enabling your organization to achieve your SOC 2 certification.
Step 4: Technology to Support Continuous Compliance
Many organizations consider SOC compliance an annual exercise, but cloud-based control environments can change quickly. Implementing a GRC solution for compliance management allows you to manage the framework, assign and track control gaps, gather evidence for attestation, and provide reports to management. If the SOC 2 controls are reviewed throughout the year, there should be no surprises during the next attestation period and audit. Subsequent SOC 2 compliance should be turnkey since the controls were monitored on an ongoing basis. The focus shifts to gathering documented evidence on an ongoing basis.
A purpose-built GRC solution can enable you to:
- Easily scope your SOC 2 requirements.
- Centralize your SOC 2 compliance data.
- Serve as an evidence repository and a history log of your compliance activities.
- Facilitate stakeholder collaboration and communication during the SOC 2 assessment.
- Efficiently perform assessments and audit preparedness through automated assessment surveys.
- Streamline issue remediation and close gaps with automated workflows and notifications to stakeholders.
- Allow third-party auditors to work in a centralized platform containing all relevant data.
As your SOC 2 compliance program matures and streamlines its activities, you can reduce the stress that comes from treating SOC 2 controls attestation and auditing as a point-in-time exercise. Ultimately, proper preparation for obtaining a positive opinion on the SOC 2 report is critical, and your compliance environment is the key to your success.
Tony Luciani is a Senior Manager of Product Solutions at AuditBoard. Prior to AuditBoard, Tony served as IT Risk and Compliance Manager at Sony Pictures. As a former InfoSec consultant, PCI QSA, and CCSFP Assessor, his experience ranges from performing gap/attestation assessments (i.e. NIST, ISO, CIS, SOC2, PCI, HITRUST, etc.) to facilitating IT risk management programs for customers across multiple industries. Connect with Tony on LinkedIn.