Operationalization of Compliance

 For many of us, being compliant with a security framework consists of uncalculated technical decisions based on a limited knowledge and understanding of the compliance framework we implemented and its reporting and compliance requirements.  Most businesses that are aligning with a compliance standard are struggling to understand and maintain scope, gather adequate security control supporting evidence, properly manage their Auditor (yes, they can be managed even disagreed with; their word is not law and most of them are not technical). That will all be repeated again every year, with costs increasing as complexity to meet the compliance standard increases.

Missed the basics? Check the Operationalization of Compliance-part 1 blog in the series: to catch up on the essentials.

 Small companies, especially, but even large companies are struggling to keep up with continuous patching, scanning and evidence gathering activities, let alone ensure that their KTLO needs are managed and oh by the way there is the whole cybersecurity thing to worry about as well.  Limited manpower and lack of proper project planning may also contribute to the consistent struggle felt by organizations for the first few years of working with a compliance framework like PCI, SOC2 Type 1 or 2, HIPAA, or CMMC.

SOC2 Overview

 Before we can talk about how to operationalize your SOC2 Type 1 or 2 Audit, we need to understand what a SOC2 audit is and what it is not in order to eliminate the primary misconception about the SOC2 audit of it being purely a technical audit. While all compliance frameworks involve the whole business, at least tangentially, the AICPA’s SOC2 audits truly involve all departments of your company, your board and even senior management. SOC2 compliance is closely related to Risk Management since the framework focuses on creating the controls that mitigate risk associated with data security and privacy.

SOC2 type 1 and 2 audits (SOC2) is based on the COSO framework, The COSO Framework is a system used to establish internal controls to be integrated into business processes. It is focused on how the business operates, not just on technical controls. COSO was designed to help organizations establish effective internal controls to ensure ethical operations, compliance with laws, and reliable financial reporting.

Five components of COSO framework:

1. Control Environment
2. Risk Assessment
3. Control Activities
4. Information and Communication
5. Monitoring Activities

Above mentioned  components  work together to manage risks and improve business processes.

In a SOC2 Type 1 or 2 audit you will be asked questions based on the COSO Principals like “Does the entity demonstrate a commitment to integrity and ethical values?” or “Does the board of directors demonstrate independence from management and exercise oversight of the development and performance of internal controls?”.

Most companies just beginning their SOC2 compliance journey are typically under the impression that SOC 2 type 1 and 2 audits are purely technical. Due to administrative and operational, not just technical questions, it is necessary to prepare all departments to be ready to participate in the audit at least for their part. The nice thing about SOC2 is that it is broken down into specific Control Criteria, typically called CC. When you adhere to the Control Criteria called out in the Trust Services Criteria (TSC) you will be able to identify potential risks to customer data and establish the processes necessary to enable your business to manage and mitigate your risks effectively. When working with a security firm like RITC Cybersecurity, they will help identify which parts of the audit require involvement from non-technical staff and guide you in developing processes to mitigate risks uncovered during audit preparation–helping keep your company secure and ahead of the curve.

What is SOC 2 Really? 

A Service Organization Controls (SOC) 2 audit will examine your organization’s controls in place that protect and secure its system or services used internally or by customers. The security posture of your organization is assessed based on the requirements within a SOC 2 examination, known as the Trust Services Criteria (TSC).

The Trust Services Criteria:

The security posture of your organization is assessed based on the requirements within a SOC 2 examination, known as the Trust Services Criteria (TSC). You are not required to be audited on all 5 and unless there is a customer requirement for additional criteria most business simply choose the Security Criteria, which is the only TSC mandatory on all audits.

The five TSC categories are as follows:

1. Security

Assesses the protection of information throughout its lifecycle there are roughly 200 criteria in the Security TSC. There are a wide range of risk-mitigating solutions that also include administrative and financial criteria. 


Below are the optional TSCs


2. Availability 
Consists of controls that show your systems maintain operational uptime and performance to meet your objectives and service level agreements (SLAs). 


3. Confidentiality
Examines your organization’s ability to protect information from collection, to processing and disposal.


4. Processing Integrity
Ensures the data your organization processes is free of accidental or unexplained errors. 


5. Privacy 
Reviews the Personally Identifiable Information (PII) that your organization captures from customers, such as social security numbers, birthdays, etc.

Now that you understand what a SOC2 audit entails–and what it doesn’t– in the next installment, we’ll explore the key benefits of undergoing a SOC2 audit, including how it builds trust with clients and strengthens your security posture. From there, we’ll dive into how to operationalize the audit process, turning it from a one-time project into a sustainable part of your organization’s workflow–ultimately making it more manageable and less disruptive for your team.

New to this topic? Check the previous blog in the series: for Operationalization of Compliance part-1 we’re building on here.

Relevant  blogs:

CCPA Compliance Checklist Ensures Data Protection & Privacy

How Cyberattacks Impact Your Business | Cybersecurity