It’s a common scenario: Your organization wants to be SOC 2 (Service Organization Control 2) compliant and assigns you to look into the framework requirements.
After some preliminary research, however, you realize that compliance requires first understanding the general guidelines set by The American Institute of Certified Public Accountants (AICPA), the creators of SOC 2, and then determining what criteria applies to your organization. It’s a complex process that usually takes several weeks to months to complete.
Thankfully, there’s a way to simplify the process — with a SOC 2 compliance checklist. Leveraging a SOC 2 checklist helps you fast-track the process of defining and implementing SOC 2 controls in your organization.
The checklist below breaks down everything you need to properly scope your program, prepare for your audit, and achieve SOC 2 compliance. Regardless of your organization’s size or program maturity, the easy-to-follow, eight-step process will not only serve as a guide but also accelerate your time to SOC 2 compliance.
Why do you need a SOC 2 compliance checklist?
SOC 2 is by far the most requested InfoSec framework and audit process in the US, signifying that an organization can be trusted to secure its customers and sensitive data.
A SOC 2 compliance checklist includes practical guidance and clear action steps to help organizations meet framework requirements. Not only does a SOC 2 checklist share critical details about each step, it also provides tips to streamline the process and strengthen your overall security posture.
We drew from years of information security experience and expertise to bring together all you need to know throughout your entire compliance journey, starting with establishing objectives and trust service principles to maintaining SOC 2 standards.
SOC 2 compliance checklist: 8 steps
Preparing for your SOC 2 audit can take months, with tasks such as defining the scope, choosing an auditor, implementing internal controls, and performing a readiness assessment as part of the typical process. Below, we break down the eight essential steps to becoming SOC 2 compliant:
1. Establish your objectives
The first item in our SOC 2 compliance checklist is to have clear, well-defined objectives. Why does your organization need SOC 2? What purpose or benefit does it offer?
A few reasons why organizations work toward SOC 2 are because it’s requested by their customers, it underpins a secure data management program, it helps communicate your security operations, and it builds trust in your brand.
No matter what the reason, establishing objectives early on ensures your efforts align with organizational goals and provides guidance when it comes time to create and implement security controls.
2. Choose your auditor
Even organizations experienced in SOC 2 compliance recommend choosing your independent or external auditor as soon as possible. After all, how often do you get to choose the individual who reviews your work?
Not only are auditors responsible for creating your final SOC 2 report, they also play a key role in helping navigate the entire process. Audit firms and service providers are one of the biggest factors in whether your organization will ultimately achieve SOC 2 compliance.
Here are a few factors to keep in mind when choosing the best auditor for you:
- Knowledge and understanding: Are they familiar with your industry and type of business? Do they provide adequate answers to your questions and suggest clear solutions?
- Ready to collaborate across teams: Unless you’re the only one who will interface with the auditor, make sure all stakeholders across teams (i.e., DevOps, third-party management, privacy) have a chance to meet and evaluate the auditor.
- Transparent about operations: Don’t just talk to their sales teams — sit down with the actual audit team. Ask them about specific compliance details, workflows, SLAs, timelines, etc.
While auditors can give guidance, OneTrust offers a SOC 2 compliance solution to further simplify and accelerate your process. It comes with pre-built controls and automation that can be customized to meet your specific organization needs.
3. Identify the type of SOC 2 report
There are two types of SOC 2 audit reports: SOC 2 Type 1 and SOC 2 Type 2.
The SOC 2 Type 1 looks at your organization’s data security and privacy controls at the time of the audit; while the SOC 2 Type 2 looks at the same controls, but over a period of time (approximately six to 12 months).
Type 1 reports are much easier and a good option if you need to show compliance in a short amount of time. However, most organizations (and their customers) will want Type 2 reports. Type 2 reports are much more intensive and go farther in proving your systems are protected by a high level of security. For this reason, many organizations opt to skip Type 1 and go directly to Type 2 compliance.
4. Define your audit scope
As with most compliance efforts, SOC 2 audits are defined by the organization’s scope. For example, a general scope can be limited to a particular location or area of operations. More commonly for SOC 2, a scope will be focused on the operations that support a specific product or service your organization offers.
Defining the SOC 2 audit scope, however, entails a thorough understanding of both your operations and the framework’s compliance requirements. Start by looking at all the applications, databases, physical locations, and systems where your customer data lives. You also need to determine which of the five Trust Services Criteria (TSC) applies to your organization.
Keep in mind that Security is mandatory for any SOC 2 audit, while the other four criteria — Availability, Processing integrity, Confidentiality, and Privacy — are optional.
By excluding any areas that aren’t relevant ahead of time, you can significantly lighten the compliance load for your organization.
5. Perform a gap assessment
Once you’ve defined your audit scope, you can then perform a gap assessment or gap analysis that compares your current security efforts to those outlined in the SOC 2 framework.
This step should be fairly simple. The aim is to quickly identify what existing security practices, policies, and technologies are in place, and uncover any gaps or issues that still need to be addressed. Examples of common gaps include lack of organizational control documentation, unauthorized access controls, or unaddressed security vulnerabilities.
Performing a proactive SOC 2 gap assessment gives you enough time to implement necessary controls and perform any risk assessments or risk mitigation before the actual audit.
Make this step as pain-free as possible with a dedicated SOC 2 compliance software like OneTrust. Automations are available to instantly scan your systems and controls, reducing the majority of manual work, human error, and completing assessments within hours rather than weeks.
6. Remediate gaps and implement security controls
Now it’s time to address all the SOC 2 compliance gaps you identified in your assessment. While the AICPA offers general guidance, it’s largely open to interpretation. It’s best to work with your teams to review policies, implement necessary changes or controls, and document any new processes.
Organizations find this the most rigorous and time-consuming part of the SOC 2 framework, as it can take some time to close the gaps between your current security process and the required compliance standards.
7. Undergo an audit simulation (Optional)
As a final step before your official audit, your auditor can perform a simulated or mock audit that assesses your readiness. Audit simulations verify whether you've implemented the correct controls and, in some cases, will highlight any changes needed to demonstrate SOC 2 compliance. These types of audits are optional, but highly recommended as a way to familiarize your organization with the actual process and bring about peace of mind.
8. Complete your SOC 2 audit
Your scope is defined. Your gaps are closed. Your policies and controls are in place. All that’s left is to go through the actual SOC 2 compliance audit. For SOC 2 Type 2, the audit process can take anywhere from a few weeks to several months, during which your auditor will review the organizational controls and systems included in your scope.
Auditors also typically ask some more questions, request additional evidence, or schedule on-site walkthroughs. Make sure to work closely with your auditor so you can align timelines and ensure everything goes smoothly.
At the end of the audit, you’ll receive a SOC 2 report summarizing your systems and controls, as well as the auditor’s findings and opinion. (Remember that unqualified opinions mean you pass! Read our other article on understanding your auditor’s SOC 2 report opinion.)
Download this checklist and start your path to SOC 2 compliance today.
Achieving your SOC 2 compliance
Congratulations! Your organization is now (hopefully) SOC 2 compliant. After taking a deep sigh of relief and displaying the SOC 2 compliance seal on your website, it’s important to establish continuous monitoring and security measures. SOC 2 audits reports are valid for 12 months and most organizations will renew their attestation reports on an annual basis.
To ensure you stay continuously compliant, a scalable platform like OneTrust can integrate into your tech stack, automatically customize a list of policies and controls for your organization, and operationalize all your SOC 2 requirements in a single location.