Skip to content

04 Perform a SOC 2 Readiness Review

Welcome to the fourth project in:

Module 11 — Enterprise GRC Transformation Project

In the previous projects, you moved through:

Enterprise Risk Assessment
Build an ISMS
ISO 27001 Gap Assessment

You learned how to evaluate an organization against an information security management system framework.

Now the organization has another business requirement.

Enterprise customers are asking:

Do You Have
a SOC 2 Report?

Sales teams are receiving security questionnaires.

Customers want assurance over:

Security
Availability
Confidentiality
Processing Integrity
Privacy

CloudNova therefore needs to understand whether its environment and control program are ready for a:

SOC 2
Examination

Your assignment is to perform a:

SOC 2
Readiness Review

Your objective is to determine whether CloudNova has the:

Governance
Processes
Controls
Ownership
Documentation
Evidence
Operational Consistency

needed to support a SOC 2 examination.

You will move through:

Business & Customer Requirements
System Boundary
Trust Services Categories
Applicable Criteria
Risk Assessment
Control Mapping
Control Ownership
Evidence
Design Assessment
Implementation Review
Operating Readiness
Gap Identification
Remediation
SOC 2 Readiness

Project Type: SOC 2 Readiness Assessment
Difficulty: Intermediate to Advanced
Estimated Time: 4–6 Hours
Primary Role: GRC Analyst / Security Compliance Analyst
Supporting Roles: CISO / Security / IT / Engineering / HR / Legal / Privacy / Procurement / Internal Audit
Framework: AICPA Trust Services Criteria
Environment: Spreadsheet, documentation platform, ticketing system, evidence repository, or GRC platform
Deliverable: SOC 2 Readiness Assessment & Remediation Pack

Important: SOC 2 examinations are performed by appropriately licensed CPA firms. This project teaches readiness methodology and does not represent an actual SOC 2 examination or opinion.

By completing this project, you will learn how to:

  • understand the purpose of SOC 2.

  • distinguish SOC 1 from SOC 2.

  • understand SOC 2 Type I and Type II.

  • understand the Trust Services Criteria.

  • select relevant Trust Services Categories.

  • define a SOC 2 system boundary.

  • identify system components.

  • identify infrastructure and software dependencies.

  • identify people, procedures, and data.

  • understand complementary controls.

  • understand subservice organizations.

  • create a SOC 2 control matrix.

  • map internal controls to applicable criteria.

  • assign control ownership.

  • evaluate control design.

  • evaluate control implementation.

  • assess operating readiness.

  • identify control evidence.

  • create an evidence request list.

  • test representative control samples.

  • identify control gaps.

  • assess remediation priority.

  • prepare a readiness dashboard.

  • create a SOC 2 remediation roadmap.

  • prepare teams for examination readiness.

CloudNova Technologies provides an enterprise SaaS platform hosted primarily in AWS.

Its customers include:

Financial Services
Healthcare
Technology Companies
Professional Services
Enterprise Customers

The sales team reports that major customers increasingly request:

SOC 2 Type II
Report

during procurement.

Some customers will not approve CloudNova without independent assurance over its security controls.

The CEO asks:

How Quickly
Can We Become
SOC 2 Ready?

The CISO asks:

Do Our Existing
ISO 27001 Controls
Support SOC 2?

The GRC team is assigned to perform a readiness review before engaging the organization’s external auditor.

Determine:

What Is
in Scope?
Which Criteria
Apply?
What Controls
Already Exist?
Who Owns
Those Controls?
Are Controls
Designed Properly?
Are They
Implemented?
Are They
Operating Consistently?
Can We
Produce Evidence?
What Gaps
Exist?
What Must
Be Fixed?

Create:

01 SOC 2 Readiness Scope
02 System Boundary
03 System Component Inventory
04 Trust Services Category Assessment
05 SOC 2 Control Matrix
06 Control Ownership Register
07 Evidence Request List
08 Control Testing Workbook
09 Gap Register
10 Finding Register
11 Remediation Plan
12 SOC 2 Readiness Dashboard
13 Management Readiness Report
14 Examination Preparation Checklist
15 SOC 2 Readiness Roadmap

SOC 2 is an assurance reporting framework used to evaluate controls relevant to the:

Security
Availability
Processing Integrity
Confidentiality
Privacy

of systems used to provide services.

SOC 2 is based on the:

AICPA
Trust Services Criteria

Part 2 — Understand the Five Trust Services Categories

Section titled “Part 2 — Understand the Five Trust Services Categories”

The five categories are:

Security
Availability
Processing Integrity
Confidentiality
Privacy

Security focuses on protecting systems and information against unauthorized access, unauthorized disclosure, and other events that could compromise the system.

Think:

Access
Threat Protection
Monitoring
Change Management
Risk Management
Security Operations

Availability considers whether systems are available for operation and use as committed or agreed.

Think:

Capacity
Resilience
Monitoring
Backup
Recovery
Business Continuity

Processing Integrity addresses whether system processing is:

Complete
Valid
Accurate
Timely
Authorized

according to system objectives.

Confidentiality focuses on information designated as confidential.

Think:

Classification
Access Restrictions
Encryption
Retention
Secure Disposal

Privacy addresses personal information and how it is:

Collected
Used
Retained
Disclosed
Disposed

according to relevant commitments and criteria.

For SOC 2, the Security category is based on the Common Criteria and is part of every SOC 2 examination.

Additional categories are selected based on:

Business Commitments
Customer Requirements
System Characteristics
Risk
Service Commitments

Part 9 — Do Not Select Categories for Marketing

Section titled “Part 9 — Do Not Select Categories for Marketing”

Weak approach:

Let's Include
All Five
Because It
Looks Better

Professional approach:

Customer Commitments
+
System Requirements
+
Risk
Relevant Trust
Services Categories

Every additional category can introduce additional criteria, controls, evidence, and examination effort.

Suppose CloudNova determines that its enterprise SaaS commitments require:

Security
Availability
Confidentiality

Privacy may require separate evaluation depending on CloudNova’s privacy commitments and system responsibilities.

Processing Integrity may also be considered if commitments regarding processing completeness, validity, accuracy, timeliness, or authorization are material.

A common source of confusion is:

Type I
vs
Type II

A Type I report addresses control design and implementation as of a specified date.

Conceptually:

Do Appropriate
Controls Exist
at This Point
in Time?

A Type II report additionally considers operating effectiveness over a specified period.

Conceptually:

Did Those
Controls Operate
Effectively Over
the Review Period?

For Type II readiness, you need more than:

Policy Exists

You need controls that:

Are Designed
Are Implemented
Operate Consistently
Generate Evidence
Can Be Tested
Over Time

SOC 1 focuses on controls relevant to:

User Entities'
Internal Control
Over Financial Reporting

SOC 2 focuses on controls relevant to the applicable:

Trust Services
Criteria

Do not use the terms interchangeably.

Before evaluating controls, define:

What System
Are We
Assessing?

This is one of the most important parts of readiness.

For CloudNova, the system might include:

Enterprise SaaS Platform
Production AWS Accounts
Kubernetes Clusters
Application Services
Databases
CI/CD Pipeline
GitHub
Identity Services
Monitoring
Security Tooling
Customer Support Systems

Part 16 — Identify Supporting Components

Section titled “Part 16 — Identify Supporting Components”

The system is not only technology.

Consider:

Infrastructure
Software
People
Procedures
Data

Examples:

AWS
Kubernetes
Networks
Compute
Storage
Databases
Load Balancers

Examples:

CloudNova Application
CI/CD Tooling
Security Platforms
Monitoring Platforms
Identity Platforms
Supporting SaaS

Include relevant:

Developers
SRE
Security
IT
Customer Support
Management
Contractors

Examples:

Access Management
Change Management
Incident Response
Vulnerability Management
Backup
Recovery
Vendor Management

Identify:

Customer Data
Authentication Data
Application Data
Logs
Backups
Configuration Data
Support Data

Part 22 — Create System Component Inventory

Section titled “Part 22 — Create System Component Inventory”

Use:

Component Type Owner Purpose In Scope
AWS Production Infrastructure Cloud Hosting Yes
Kubernetes Infrastructure Platform Workloads Yes
GitHub Software/SaaS Engineering Source Code Yes
Microsoft 365 SaaS IT Corporate Services Review
SIEM Security SOC Monitoring Yes

Part 23 — Understand Subservice Organizations

Section titled “Part 23 — Understand Subservice Organizations”

CloudNova relies on external organizations such as:

AWS
Identity Providers
SaaS Providers
Payment Providers
Support Platforms

These may be:

Subservice
Organizations

depending on their role in delivering the system.

Part 24 — Determine Treatment of Subservice Organizations

Section titled “Part 24 — Determine Treatment of Subservice Organizations”

Understand whether the system description uses an approach such as:

Carve-Out

or:

Inclusive

for relevant subservice organizations.

This decision should be made with the organization’s auditor and reporting strategy.

Part 25 — Complementary Subservice Organization Controls

Section titled “Part 25 — Complementary Subservice Organization Controls”

CloudNova may depend on controls operated by service providers.

Example:

CloudNova
Uses AWS
AWS Operates
Certain Physical
and Infrastructure
Controls

CloudNova must still understand its responsibilities under the shared-responsibility model.

Part 26 — Complementary User Entity Controls

Section titled “Part 26 — Complementary User Entity Controls”

Customers may also have responsibilities.

These may be described as:

Complementary
User Entity
Controls

For example:

Customer
Must Protect
Administrator
Credentials

Part 27 — Understand Entity-Level Controls

Section titled “Part 27 — Understand Entity-Level Controls”

SOC 2 readiness is not only technical.

Evaluate enterprise controls around:

Governance
Ethics
Accountability
Risk Management
Communication
Monitoring

Control design should follow:

Service Commitments
System Requirements
Risk
Criteria
Controls

not:

SOC 2 Checklist
Create Random
Controls

Part 29 — Reuse the Enterprise Risk Assessment

Section titled “Part 29 — Reuse the Enterprise Risk Assessment”

CloudNova already identified risks including:

Privileged Account Compromise
Cloud Misconfiguration
Critical Vulnerabilities
Ransomware
Third-Party Compromise
Service Outage
Data Exposure
Software Supply-Chain Risk

These risks can help determine appropriate controls.

Create:

Control ID
Control Name
Control Objective
Control Description
Applicable Criterion
Risk
Control Owner
Frequency
Evidence
Control Type
Status
Control ID:
IAM-001
Control:
Privileged MFA
Objective:
Protect privileged
accounts from
unauthorized access.
Owner:
IAM Manager
Frequency:
Continuous
Evidence:
Identity configuration
and account reports

Part 32 — One Control Can Support Multiple Criteria

Section titled “Part 32 — One Control Can Support Multiple Criteria”

Avoid assuming:

One Criterion
=
One Control

An enterprise control may support multiple requirements.

Example:

Quarterly
Privileged Access Review

may support several security-related criteria.

CloudNova already has controls from its ISMS.

Instead of:

ISO Controls
+
Separate SOC 2 Controls

build:

Enterprise
Common Controls
ISO 27001
Mapping
+
SOC 2
Mapping

Example:

Internal Control
IAM-001
ISO Mapping
SOC 2 Mapping
NIST Mapping
Customer Requirement

This reduces duplicate control management.

For every control ask:

Would This Control,
If Performed
as Designed,
Address the
Relevant Risk?

Risk:

Former Employee
Retains Access

Control:

HR Emails IT
When Someone
Leaves

This may work.

But ask:

Is It Timely?
Is It Complete?
Who Tracks It?
What Happens
If Email Is Missed?
Can It Be Proven?
HR Termination
Record Created
Automated Workflow
Identity Access
Disabled
Ticket Generated
Completion Verified
Exception Escalated

A well-designed control is not useful if:

Nobody
Implemented It

Verify:

Configuration
Procedure
Ownership
Workflow
Evidence

For Type II preparation, ask:

Has the Control
Operated Consistently
Across the Intended
Period?

Control:

Quarterly
Access Review

Evidence:

Q1 ✓
Q2 ✓
Q3 Missing
Q4 ✓

Conclusion:

Control Exists
Design May
Be Appropriate
Operation
Is Inconsistent

Controls may operate:

Continuous
Daily
Weekly
Monthly
Quarterly
Annually
Event-Driven

Frequency affects evidence expectations and sampling.

Every control should answer:

Who Is
Accountable
for This Control?

Examples:

IAM
→ Access Controls
Security Engineering
→ Vulnerability Controls
SOC
→ Monitoring
Engineering
→ Change Controls
HR
→ Personnel Controls
TPRM
→ Vendor Controls
BCM
→ Recovery Controls
Control Owner Operator Evidence Owner Frequency
Privileged MFA IAM IAM IAM Continuous
Access Review IAM IAM IAM Quarterly
Vulnerability Scan Security Security Security Weekly
Vendor Review TPRM GRC TPRM Risk-Based

Part 44 — Establish Evidence Requirements

Section titled “Part 44 — Establish Evidence Requirements”

SOC 2 readiness requires:

Control
Operation
Evidence

Evidence should be produced through normal control operation.

Examples include:

Policies
System Configurations
System-Generated Reports
Tickets
Approvals
Logs
Access Reviews
Change Records
Incident Records
Training Records
Vendor Assessments
Recovery Tests
Meeting Minutes

Good evidence should be:

Relevant
Reliable
Complete
Accurate
Current
Traceable

Depending on the control, stronger evidence often includes:

System-Generated
Evidence

rather than relying solely on:

Manual
Screenshots

Screenshots can still be useful, but they may require additional context and validation.

Example:

ID Control Evidence Owner Frequency Status
E-001 IAM-001 MFA Export IAM Continuous Ready
E-002 IAM-002 Access Review IAM Quarterly Partial
E-003 VM-001 Scan Report Security Weekly Ready
E-004 BCM-001 DR Test BCM Annual Missing

Suggested:

SOC2-Evidence
├── Governance
├── Risk
├── IAM
├── Asset Management
├── Change Management
├── Vulnerability Management
├── Logging
├── Incident Response
├── Vendor Management
├── Business Continuity
├── HR
└── Privacy

Part 50 — Avoid Auditor-Specific Evidence Silos

Section titled “Part 50 — Avoid Auditor-Specific Evidence Silos”

Weak:

ISO Evidence
SOC 2 Evidence
Customer Evidence

Better:

Enterprise
Control Evidence
Multiple
Assurance Uses

Review:

Security Governance
Roles & Responsibilities
Policies
Risk Management
Management Oversight
Control Monitoring

Review:

User Provisioning
Authentication
MFA
Privileged Access
Access Reviews
Termination
Service Accounts
Access Exceptions

Review:

Asset Inventory
Ownership
Classification
Lifecycle
Cloud Resources
Endpoints
Software

Review:

Change Request
Authorization
Testing
Approval
Deployment
Emergency Changes
Rollback
Code Change
Pull Request
Peer Review
Automated Testing
Approval
Deployment
Logging

Select changes and verify:

Request
Approval
Testing
Reviewer
Deployment
Segregation
Traceability

Part 57 — Evaluate Vulnerability Management

Section titled “Part 57 — Evaluate Vulnerability Management”

Review:

Scanning
Prioritization
Remediation SLA
Exception Management
Validation
Reporting
Scanner Report
Critical Finding
Ticket
Assigned Owner
Remediation
Rescan
Closure

Review:

Logging
SIEM
Alerting
Triage
Escalation
Incident Creation
Retention

Select alerts and trace:

Security Event
Alert
Analyst Review
Disposition
Escalation
Incident

Review:

Incident Policy
Response Plan
Roles
Detection
Escalation
Communication
Investigation
Recovery
Lessons Learned

Verify:

Incident Record
Severity
Timeline
Actions
Communication
Closure
Lessons Learned

Review:

Vendor Inventory
Risk Classification
Due Diligence
Security Assessment
Contract Requirements
Monitoring
Reassessment
Termination

Focus on providers that could materially affect:

Security
Availability
Confidentiality
Privacy
Processing

If Availability is in scope, review:

Business Impact Analysis
Recovery Requirements
Backup
Redundancy
Disaster Recovery
Testing
Capacity
Monitoring

Determine:

What Is Backed Up?
How Often?
Where?
How Is It Protected?
Is Restore Tested?
Who Reviews Failures?

Evidence may include:

Test Plan
Participants
Scenario
Recovery Results
RTO Results
RPO Results
Failures
Lessons Learned
Remediation

Part 68 — Evaluate Confidentiality Controls

Section titled “Part 68 — Evaluate Confidentiality Controls”

If Confidentiality is selected, evaluate areas such as:

Data Classification
Access Restrictions
Encryption
Data Transfer
Retention
Secure Disposal

If Privacy is selected, evaluate the organization’s privacy commitments and applicable criteria across relevant personal-information lifecycle activities.

Potential areas include:

Notice
Choice / Consent
Collection
Use
Retention
Access
Disclosure
Quality
Monitoring

The exact assessment should follow the applicable Trust Services Criteria and organizational commitments.

Review:

Background Screening
Security Agreements
Onboarding
Training
Role Changes
Termination
Confidentiality

Evidence may include:

Training Content
Employee Population
Completion Records
Reminders
Exceptions
Phishing Exercises

Trace:

Employee
Approved Role
Access Request
Approval
Provisioning
Periodic Review
Modification
Termination

Select new employees.

Verify:

Request
Approval
Role
Access
Provisioning Date

Select employees who changed roles.

Verify:

Old Access
New Role
Required Access
Removed Access
Approval

Select terminated personnel.

Verify:

Termination Date
Notification
Account Disablement
Privileged Access
Tokens
Devices

Controls may have exceptions.

Examples:

MFA Exception
Vulnerability Exception
Emergency Change
Access Exception

Every exception should have appropriate:

Justification
Approval
Risk Evaluation
Compensating Control
Expiration
Review

Common gaps may include:

Missing Control
Weak Control Design
Control Not Implemented
Inconsistent Operation
Missing Evidence
Unclear Ownership
Missing Review
Unmanaged Exception
Incomplete Population
Missing Monitoring

Example:

Gap Area Issue Risk Priority
G-001 IAM Access review missed High High
G-002 BCM Restore testing incomplete High High
G-003 TPRM Vendor reassessment overdue Medium Medium
G-004 HR Training evidence incomplete Medium Medium

Weak:

Access Review
Missing

Better:

The quarterly privileged
access review was not
completed during Q2.
Evidence was available
for Q1 and Q3, but
no evidence was available
for Q2.

Use:

Criteria
Control
Condition
Evidence
Risk
Recommendation

Do not stop at:

Control
Failed

Ask:

Why Did
It Fail?

Gap:

Vendor Reviews
Overdue

Why?

No Reminder

Why?

No Central
Review Calendar

Why?

Vendor Governance
Not Integrated
Into GRC Workflow

Better action:

Centralize Vendor Inventory
Assign Risk Tier
Define Review Frequency
Automate Reminder
Escalate Overdue Reviews
Track Evidence

Record:

Gap ID
Action
Owner
Priority
Dependencies
Target Date
Expected Evidence
Status
Retest Result

Do not close because:

Policy
Created

Validate:

Control Designed
Implemented
Operated
Evidence Generated
Retested

Part 86 — Prepare for Observation Period

Section titled “Part 86 — Prepare for Observation Period”

For a Type II examination, operating history matters.

A control introduced:

Yesterday

cannot demonstrate months of prior operation.

Therefore readiness planning must consider:

Control Implementation
Stabilization
Evidence Generation
Operating Period
Examination

The exact examination period and expectations should be coordinated with the CPA firm performing the engagement.

Example:

Control Frequency Owner Evidence
Access Review Quarterly IAM Review Report
Vulnerability Scan Weekly Security Scanner Report
Vendor Review Risk-Based TPRM Assessment
DR Test Annual BCM Test Report
Training Annual HR Completion Report

Track:

Control
Expected Date
Evidence Due
Owner
Collected
Reviewed
Exception

Mature organizations move from:

Auditor Requests
Evidence
Everyone Searches
for Files

to:

Control Operates
Evidence Generated
Evidence Stored
Evidence Validated
Audit Ready

Example:

SOC 2 READINESS
Controls Identified 75
Controls Implemented 69
Controls Operating 64
Evidence Ready 60
High Gaps 5
Medium Gaps 11
Overdue Controls 3
Readiness Blockers 2

Values are illustrative.

Part 91 — Do Not Rely Only on a Percentage

Section titled “Part 91 — Do Not Rely Only on a Percentage”

Avoid:

SOC 2 Ready
92%

without explaining:

Which Controls
Are Missing?
Which Controls
Failed?
Which Evidence
Is Missing?
Which Gaps
Could Affect
the Examination?

Examples might include:

Undefined System Boundary
Incomplete Risk Assessment
Critical Controls Missing
Key Controls Not Operating
Insufficient Evidence
Major Access Weaknesses
No Vendor Governance
Untested Recovery

Actual significance depends on scope, criteria, control design, and the auditor’s evaluation.

Example:

Domain Status
Governance High
Risk Management High
IAM Medium
Change Management High
Vulnerability Management Medium
Monitoring High
Incident Response High
Vendor Risk Medium
Business Continuity Medium
Evidence Readiness Medium

Management wants to know:

Are We Ready?
What Are
the Biggest Gaps?
What Could
Delay the Examination?
What Must
Be Fixed?
Who Owns
the Work?
What Resources
Are Required?
When Can We
Begin the
Operating Period?

Create:

Objective
Scope
Trust Services Categories
System Boundary
Overall Readiness
Key Strengths
Critical Gaps
High-Risk Gaps
Evidence Readiness
Remediation Priorities
Resource Requirements
Recommended Timeline
Management Decisions
CloudNova has established
a substantial security
control environment through
its existing ISMS.
Many existing controls can
support SOC 2 requirements.
Readiness gaps remain in
privileged access reviews,
vendor monitoring,
recovery testing, and
evidence consistency.
These gaps should be
remediated and operating
evidence established before
progressing into the intended
Type II examination period.

Your previous project created:

ISO 27001
Control Environment

Now map it:

Enterprise Control
ISO 27001
+
SOC 2
Risk:
Unauthorized Access
Control:
IAM-001 MFA
ISO Mapping
SOC 2 Mapping
Evidence:
Identity Report

Part 99 — One Control, Multiple Assurance Uses

Section titled “Part 99 — One Control, Multiple Assurance Uses”

The professional goal is:

One Control
One Owner
One Process
One Evidence Source
Multiple Frameworks

not:

ISO Control
SOC Control
Customer Control
NIST Control

all independently managed.

Suggested domains:

GOV — Governance
RISK — Risk Management
IAM — Identity & Access
AST — Asset Management
CHG — Change Management
VM — Vulnerability Management
LOG — Logging & Monitoring
IR — Incident Response
TPRM — Third-Party Risk
BCM — Business Continuity
HR — Human Resources
DATA — Data Protection
IAM-001
Privileged MFA
IAM-002
Quarterly Privileged
Access Review
IAM-003
User Termination
VM-001
Vulnerability Scanning
VM-002
Critical Vulnerability
Remediation

Maintain:

Risk
Control
SOC 2 Criterion
Owner
Evidence
Testing
Finding
Remediation
Risk Control Criterion Evidence Result
Unauthorized Access IAM-001 Applicable TSC MFA Report Pass
Excess Access IAM-002 Applicable TSC Review Partial
Vulnerability VM-001 Applicable TSC Scan Pass

Use the organization’s licensed/current Trust Services Criteria materials when recording exact criterion references.

Determine:

What Evidence
Must Be Retained?
For How Long?
Where?
Who Can Access It?
How Is Integrity
Protected?

Retention should reflect examination needs and applicable business, legal, contractual, and regulatory requirements.

Control owners should understand:

What Control
Do I Own?
How Often
Does It Operate?
What Evidence
Must I Produce?
Where Is
Evidence Stored?
What Happens
If It Fails?
Who Must
I Notify?

Part 106 — Conduct Control Owner Workshops

Section titled “Part 106 — Conduct Control Owner Workshops”

Meet with:

IAM
Engineering
Cloud
Security
SOC
HR
Procurement
BCM
Legal
Privacy

Walk through:

Control
Procedure
Evidence
Exceptions
Testing

Part 107 — Perform Mock Evidence Request

Section titled “Part 107 — Perform Mock Evidence Request”

Simulate:

Auditor Requests
Q2 Access Review

Measure:

Can We Find It?
Is It Complete?
Is It Approved?
Does It Match
the Population?
Can We Explain It?

For example, select:

10 Joiners
10 Leavers
10 Changes
5 Incidents
5 Vendors

Sample sizes here are for training only.

Actual testing and sample selection are determined by the auditor based on the engagement.

Typical problems:

Missing Approval
Wrong Date
Incomplete Population
No Owner
No Timestamp
Screenshot Without Context
Evidence Stored
in Personal Folder
Ticket Closed
Without Validation

Move toward:

System-Generated
Centralized
Repeatable
Traceable
Reviewable

evidence.

Part 111 — Build Examination Preparation Checklist

Section titled “Part 111 — Build Examination Preparation Checklist”

Before moving forward, verify:

System Boundary Defined?
Categories Selected?
Risks Assessed?
Controls Mapped?
Control Owners Assigned?
Controls Implemented?
Evidence Available?
Exceptions Managed?
Testing Completed?
Gaps Remediated?
Operating Period Planned?
Management Ready?

Part 112 — Common Mistake: Buying a Tool First

Section titled “Part 112 — Common Mistake: Buying a Tool First”

Weak:

Buy Compliance
Automation Tool
Assume
SOC 2 Ready

A tool may automate:

Evidence Collection
Monitoring
Control Tracking

but it cannot replace:

Governance
Risk Decisions
Control Design
Ownership
Operational Discipline

Part 113 — Common Mistake: Copying Controls

Section titled “Part 113 — Common Mistake: Copying Controls”

Do not simply copy:

Generic SOC 2
Control List

Controls must reflect:

CloudNova's
Systems
Risks
Processes
Commitments

Part 114 — Common Mistake: Policies Without Evidence

Section titled “Part 114 — Common Mistake: Policies Without Evidence”
Policy:
Access Reviewed
Quarterly

does not prove:

Quarterly Reviews
Actually Happened

Part 115 — Common Mistake: Evidence Created for Audit

Section titled “Part 115 — Common Mistake: Evidence Created for Audit”

Weak:

Audit Coming
Create Evidence

Better:

Control Operation
Evidence Generated
Automatically

Part 116 — Common Mistake: Ignoring Exceptions

Section titled “Part 116 — Common Mistake: Ignoring Exceptions”

Auditors may discover:

Control Works
for 98%

but the unmanaged:

2%

may represent significant risk.

Part 117 — Common Mistake: Unclear Ownership

Section titled “Part 117 — Common Mistake: Unclear Ownership”

If the answer to:

Who Owns
This Control?

is:

Security Team

ownership may be too vague.

Prefer:

Named Role
Defined Accountability

Including unnecessary systems can create:

More Controls
More Evidence
More Testing
More Exceptions
More Cost

Define the system boundary based on the services and commitments being reported upon.

Part 119 — Common Mistake: Under-Scoping

Section titled “Part 119 — Common Mistake: Under-Scoping”

Do not exclude systems that materially support the service simply to reduce effort.

The system description must accurately represent the service and its relevant components.

Part 120 — Common Mistake: Ignoring Vendors

Section titled “Part 120 — Common Mistake: Ignoring Vendors”

A SaaS organization may depend heavily on:

Cloud
Identity
Monitoring
Support
Development
Payment
Communication

providers.

Third-party dependencies must be understood.

Part 121 — Common Mistake: Treating SOC 2 as Certification

Section titled “Part 121 — Common Mistake: Treating SOC 2 as Certification”

SOC 2 is an:

Attestation
Report

not a traditional certification like ISO/IEC 27001 certification.

Use terminology carefully.

Controls Exist
Informally
Controls
Documented
Controls
Operating
Consistent
Evidence
Available
Controls
Evidence
Monitoring
Exceptions
Testing
Governance

operate as an integrated assurance system.

Move from:

Compliance Request
Find Evidence
Fix Problem
Respond

to:

Enterprise Controls
Continuous Operation
Evidence Generation
Control Monitoring
Exception Management
Continuous Assurance

Perform the SOC 2 readiness review for CloudNova.

Document:

Infrastructure
Software
People
Procedures
Data
Third Parties

Task 2 — Select Trust Services Categories

Section titled “Task 2 — Select Trust Services Categories”

Determine whether CloudNova requires:

Security
Availability
Processing Integrity
Confidentiality
Privacy

and document the rationale.

Identify at least:

20 System
Components

Create at least:

30 Enterprise
Controls

across:

Governance
Risk
IAM
Asset Management
Change Management
Vulnerability Management
Monitoring
Incident Response
Vendor Risk
BCM
HR
Data Protection

Every control must have:

Accountable Owner
Operator
Evidence Owner

Identify at least:

30 Evidence
Artifacts

Determine:

Effective Design
Partial Design
Ineffective Design

using a documented internal readiness methodology.

Determine whether each control is:

Implemented
Partially Implemented
Not Implemented

For recurring controls, inspect representative evidence across the relevant period.

Sample:

Joiners
Movers
Leavers
Changes
Incidents
Vulnerabilities
Vendors

Identify at least:

15 Realistic
Readiness Gaps

Perform root-cause analysis for at least:

5 High-Priority
Gaps

For each high-priority gap define:

Action
Owner
Target Date
Evidence
Success Criteria

Summarize:

Control Status
Evidence Status
Gap Severity
Remediation
Readiness Blockers

Answer:

Are We Ready?
What Is Missing?
What Could
Delay Us?
What Must
Management Decide?
When Can We
Move Forward?
  • service commitments understood.

  • system boundary defined.

  • infrastructure identified.

  • software identified.

  • people identified.

  • procedures identified.

  • data identified.

  • relevant third parties identified.

  • Security included.

  • additional categories evaluated.

  • selection rationale documented.

  • applicable criteria identified.

  • internal controls mapped.

  • controls defined.

  • control objectives documented.

  • owners assigned.

  • frequencies established.

  • design evaluated.

  • implementation validated.

  • operation reviewed.

  • evidence requirements identified.

  • evidence owners assigned.

  • evidence collected.

  • evidence quality reviewed.

  • repository established.

  • traceability maintained.

  • populations identified.

  • representative samples selected.

  • control operation evaluated.

  • exceptions documented.

  • failed samples investigated.

  • results recorded.

  • subservice organizations identified.

  • relevant responsibilities understood.

  • vendor controls assessed.

  • customer responsibilities considered where relevant.

  • gaps clearly documented.

  • evidence referenced.

  • risk identified.

  • root causes considered.

  • recommendations developed.

  • priorities assigned.

  • owners assigned.

  • target dates established.

  • evidence requirements defined.

  • success criteria established.

  • remediation retesting planned.

  • readiness blockers identified.

  • control calendar established.

  • evidence calendar established.

  • operating period considered.

  • management report completed.

  • next steps agreed.

04 Perform a SOC 2 Readiness Review
├── 01 SOC 2 Readiness Scope
├── 02 System Boundary
├── 03 System Component Inventory
├── 04 Trust Services Category Assessment
├── 05 SOC 2 Control Matrix
├── 06 Control Ownership Register
├── 07 Evidence Request List
├── 08 Control Testing Workbook
├── 09 Gap Register
├── 10 Finding Register
├── 11 Remediation Plan
├── 12 SOC 2 Readiness Dashboard
├── 13 Management Readiness Report
├── 14 Examination Preparation Checklist
└── 15 SOC 2 Readiness Roadmap

You successfully complete this project when you can move from:

Customer
Assurance Requirement
SOC 2 Scope
System Boundary
Trust Services Criteria
Enterprise Risk
Controls
Ownership
Operation
Evidence
Testing
Gaps
Remediation
Readiness

and answer:

What System
Is In Scope?
Which Trust Services
Categories Apply?
Which Risks
Matter?
Which Controls
Address Them?
Who Owns
Each Control?
Are Controls
Designed Appropriately?
Are They
Implemented?
Do They
Operate Consistently?
Can We
Produce Evidence?
What Exceptions
Exist?
Which Gaps
Could Affect Readiness?
What Must
Be Remediated?
Are We Ready
to Proceed?

This project reflects work performed by:

GRC Analysts
SOC 2 Readiness
Consultants
Security Compliance
Analysts
Security Assurance
Professionals
Internal Auditors
GRC Consultants
Security Governance
Managers

A beginner may approach SOC 2 as:

Checklist
Collect Evidence
Pass Audit

A professional approaches it as:

Business Commitments
System
Risk
Criteria
Controls
Ownership
Evidence
Operating Effectiveness
Independent Assurance

The goal is not simply:

Get a
SOC 2 Report

The goal is to build a control environment capable of providing:

Consistent
Repeatable
Evidence-Based
Independent
Assurance

➡️ Next: 05 — Conduct a PCI-DSS Assessment

You have now completed:

Enterprise Risk Assessment
Build an ISMS
ISO 27001 Gap Assessment
SOC 2 Readiness Review

The next project moves into a more prescriptive compliance environment:

Payment Card
Security

You will learn how to determine:

Where Cardholder
Data Exists
How Payment Data
Flows
What Systems
Are In Scope
How Scope
Can Be Reduced
Which PCI DSS
Requirements Apply
What Controls
Are Required
What Evidence
Demonstrates Compliance
Where Compliance
Gaps Exist

You will move through:

Payment Environment
Cardholder Data Flow
PCI Scope
CDE
Connected Systems
Segmentation
PCI DSS Requirements
Control Assessment
Evidence
Gap Analysis
Remediation
Compliance Readiness

➡️ Next: 05 — Conduct a PCI-DSS Assessment