SOC 2 mapping: Infrastructure and data security

SOC 2 controls mapping

With the risk landscape changing every single day due to a number of different reasons like constantly evolving cyber-attacks to changing regulatory requirements, it can be hard enough for organizations to thrive in the modern digital world. And that’s if they already have a foothold in the industry. Newer organizations need to prove that they are serious competitors by first showcasing they can handle the rigors of the threats to their customer data. 

This is where SOC 2 (Service Organization Control 2) framework comes in for service organizations. Mapping it to your current infrastructure is a surefire way to protect user data, comply with regulatory requirements, and gain a competitive edge by demonstrating that you are committed to data security and privacy.

In this article, we’ll cover some of the data-related nuances of mapping your internal processes to the SOC 2 standards as well as the key concepts to take into consideration when looking to successfully implement it within the context of your specific infrastructure. 

Defining SOC 2

At its core, SOC 2 is a framework that assesses and evaluates all aspects of data security housed within a service organization. If the bulk of your services uses cloud computing, managed services, or data centers as part of the underlying infrastructure, then there is a very high likelihood that you are quite familiar with SOC 2 guidelines. Following the guidelines and obtaining compliance can be a huge competitive boost to your organization as it demonstrates how seriously you take user data security. 

Obtaining compliance

While becoming SOC 2 compliant is a major competitive advantage, getting it is not easy. Audits are conducted by the AICPA (American Institute of Certified Public Accountants) to see how close you can line up to a set of predefined principles from the Trust Services Criteria. These principles are pinpointed on five key elements:

  • Security
  • Availability
  • Processing integrity
  • Confidentiality
  • Privacy 

How well an organization can execute each of these principles will give auditors insight into how successful the controls are that are safeguarding user data, information confidentiality, as well as regulatory compliance. 

Most organizations will need to undergo a rigorous auditing process in at least one of the principal areas where the auditors review documentation and conduct interviews with employees as well as test the effectiveness of the controls in place. This can take a long period. It’s also why it is such a competitive advantage—it demonstrates you operate data securely under a high standard. 

Key benefits

In addition to attracting more customers since you have gone through such a rigorous auditing process, having the key controls in place to obtain the attestation will push your organization to become more efficient and streamline your internal infrastructure. Having sustainable security practices means that there is no question over certain security practices like using multi-factor authentication and documentation establishment policies. 

employee using mobile phone for multi-factor authentication

It will also allow you to save time in the long run by not having to put out fires when they crop up because you have a set system in place that has been tested thoroughly. This will give you more time to improve and invest in your core service offerings that lead to greater quality service. 

SOC 2 Common Criteria

Whereas organizations can choose one Trust Services Criteria element to narrow the scope of the audit, all organizations must include the SOC 2 Common Criteria across all of their security controls. 

Data security across processing, transmission, and storage, as well as how vulnerabilities are monitored and prevented are key aspects of the common criteria list which include: 

  1. CC1 — Control environment
    Does the organization value integrity and security?
  2. CC2 — Communication and Information
    Are policies and procedures in place to ensure security? Are they communicated well to both internal and external partners?
  3. CC3 — Risk Assessment
    Does the organization analyze risk and monitor how changes impact that risk?
  4. CC4 — Monitoring Controls
    Does the organization monitor, evaluate, and communicate the effectiveness of its controls?
  5. CC5 — Control Activities
    Are the proper controls, processes, and technologies in place to reduce risk?
  6. CC6 – Logical and Physical Access Controls
    Does the organization encrypt data? Does it control who can access data and restrict physical access to servers?
  7. CC7 – System Operations
    Are systems monitored to ensure they function properly? Are incident response and disaster recovery plans in place?
  8. CC8 – Change Management
    Are material changes to systems properly tested and approved beforehand?
  9. CC9 – Risk Mitigation
    Does the organization mitigate risk through proper business processes and vendor management?

Answering these questions for your specific infrastructural processes with as much detail as possible alongside input from key stakeholders will greatly shore up potential vulnerabilities and get you closer to obtaining the coveted SOC 2 attestation. 

The building blocks of SOC 2 mapping

Before diving into the details of how to map your controls to SOC 2 requirements, it’s important to understand the foundational elements you should approach this whole process from. 

Scoping

Your efforts to align with SOC 2 requirements will be rendered moot without a clear topline strategy to build off of. Having focused and targeted scopes based on business objectives will help to determine which relevant systems and processes are used to achieve the objectives. 

Gap analysis

When we conduct a gap analysis, we want to understand where your existing controls are and where they need to be to meet requirements for SOC2. What is the gap between the two and what specific controls are falling short of SOC 2 criteria? Answering this can be key to figuring out where your greater data management shortfall might be. 

Risk analysis

It seems like we talk about risk management all the time but it’s for good reason. Identifying where your potential vulnerabilities are before making any drastic changes, whether or not you are trying to align with SOC 2, is a prudent move for any organization looking to keep an airtight seal on sensitive data. Continuous testing and analysis protocols of how well your existing controls minimize the impact of unexpected events should be built into your daily operations.  


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Mapping your controls to SOC 2 criteria

Managing to map technical and non-technical measures like access controls, risk assessment, and incident response is one of the key aspects of a successful SOC 2 attestation process. Implementing robust policies, procedures, and technical measures to protect against system breaches and unauthorized access should be the primary goal for your operations. 

As we mentioned earlier, the framework primarily relies on the Trust Services Criteria (TSC) and specifically its five categories: 

Security

Security mapping for SOC 2 revolves around two key areas: narrowing access control and shoring up network vulnerabilities. User access management creates, modifies, and terminates user accounts in conjunction with current job responsibilities and can include multi-factor authentication for strong authentication locks. 

Additional access controls like privileged access management monitor privileged accounts that might store important data and sensitive information. Failing to secure these controls can result in major system failures from cyber attacks like malware and ransomware. 

On the other hand, network security should be implemented to protect against network-based attacks. System hardening and vulnerability management can secure system configurations and scan and patch systems to address critical vulnerabilities. 

Availability

Ensuring services are available and accessible for end users is a key component for successfully mapping to SOC 2. Availability controls include:

  • Redundancy and fault tolerance to make sure service remains available in the face of a disruption
  • Monitoring mechanisms to make sure operations stay consistent
  • Backup and recovery of important data 
  • Change management processes to minimize the risk of negative impacts

Processing integrity

Data processing integrity ensures that the system is processing accurate, complete, and timely data. Data validation and error detection and reconciliation processes are major elements of this control when mapping to SOC 2. Inaccurate or stale data that hasn’t been run through these systems can lead to poor decision-making and, thus, security risks that could lead to financial damage and reputational harm. 

Confidentiality

Confidentiality control requirements include implementing data loss prevention measures as well as confidentiality agreements with employees and third-party vendors. With confidentiality, it’s important to emphasize that everyone who creates, transfers, and modifies data becomes an official steward of the data, backed by company policy. 

Privacy

The main issue when it comes to privacy controls is how data is used to leverage business growth. First and foremost, privacy controls should be implemented to protect personal information and comply with privacy laws. This means that organizations need to implement a process for how data is collected, shared, and used. Consent management, data breach notification procedures, and vendor management controls can all be used to ensure security is the number one priority. 

google chrome privacy notice

Implementation 

So you’ve figured out your controls and are working towards aligning them with your current processes. But it still feels like you are working in a vacuum. That is because you need to make specific considerations for actual implementation. 

Leadership support

First off is executive buy-in. The reality is that aligning with SOC 2 could abruptly change the processes that your key decision-makers have grown accustomed to. They might even push back on your proposed policy changes. As a result, it will be paramount that you communicate the benefits as well as build a business case around why mapping could lead to better returns. If you need help with this, a trusted compliance partner can be extremely beneficial. 

Documentation and fine-tuning

Once you’ve got proper buy-in, you can start identifying gaps in your existing processes and establishing the necessary policies and procedures to close those gaps. Documenting changes made to controls, getting evidence of control effectiveness, and gathering information on control compliance helps when it comes time for implementation and fine-tuning of your program as you’ll inevitably, need to make changes along the way. Documentation also becomes critical when asked to provide evidence during auditor assessments.

Continuous monitoring

Achieving SOC 2 compliance is just the first step in an ongoing process that will make your organization a long-term leader in user data security. Ongoing monitoring and robust remediation processes that take into account the obstacles towards data enrichment and compliance are vital to protecting large swathes of sensitive information. Periodic risk assessments and building processes that test for control deficiencies are pathways toward making sure your organization has a sustained SOC 2 compliance protocol in place. 

Mapping to the SOC 2 compliance framework might be a very complex undertaking but the rewards can definitely justify the efforts. With cyber-attack volume and sophistication on the rise throughout the world, being SOC 2 compliant not only puts in place a high standard of data protection mechanisms but also demonstrates to the rest of the market that you are not playing around when it comes to securing user data. While it is challenging, defining your scope and mapping to the specific criteria will take you far in building trust and strengthening your security posture across customers, partners, and key stakeholders. If you think you might not want to go at it alone, don’t hesitate to reach out to an expert today. 

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