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 AssessmentYou 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 Havea SOC 2 Report?Sales teams are receiving security questionnaires.
Customers want assurance over:
Security
Availability
Confidentiality
Processing Integrity
PrivacyCloudNova therefore needs to understand whether its environment and control program are ready for a:
SOC 2ExaminationYour assignment is to perform a:
SOC 2Readiness ReviewProject Objective
Section titled “Project Objective”Your objective is to determine whether CloudNova has the:
Governance
Processes
Controls
Ownership
Documentation
Evidence
Operational Consistencyneeded 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 ReadinessMission Information
Section titled “Mission Information”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.
Learning Objectives
Section titled “Learning Objectives”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.
Scenario
Section titled “Scenario”CloudNova Technologies provides an enterprise SaaS platform hosted primarily in AWS.
Its customers include:
Financial Services
Healthcare
Technology Companies
Professional Services
Enterprise CustomersThe sales team reports that major customers increasingly request:
SOC 2 Type IIReportduring procurement.
Some customers will not approve CloudNova without independent assurance over its security controls.
The CEO asks:
How QuicklyCan We BecomeSOC 2 Ready?The CISO asks:
Do Our ExistingISO 27001 ControlsSupport SOC 2?The GRC team is assigned to perform a readiness review before engaging the organization’s external auditor.
Your Mission
Section titled “Your Mission”Determine:
What Isin Scope?
Which CriteriaApply?
What ControlsAlready Exist?
Who OwnsThose Controls?
Are ControlsDesigned Properly?
Are TheyImplemented?
Are TheyOperating Consistently?
Can WeProduce Evidence?
What GapsExist?
What MustBe Fixed?Required Deliverables
Section titled “Required Deliverables”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 RoadmapPart 1 — Understand SOC 2
Section titled “Part 1 — Understand SOC 2”SOC 2 is an assurance reporting framework used to evaluate controls relevant to the:
Security
Availability
Processing Integrity
Confidentiality
Privacyof systems used to provide services.
SOC 2 is based on the:
AICPATrust Services CriteriaPart 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
PrivacyPart 3 — Security
Section titled “Part 3 — Security”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 OperationsPart 4 — Availability
Section titled “Part 4 — Availability”Availability considers whether systems are available for operation and use as committed or agreed.
Think:
Capacity
Resilience
Monitoring
Backup
Recovery
Business ContinuityPart 5 — Processing Integrity
Section titled “Part 5 — Processing Integrity”Processing Integrity addresses whether system processing is:
Complete
Valid
Accurate
Timely
Authorizedaccording to system objectives.
Part 6 — Confidentiality
Section titled “Part 6 — Confidentiality”Confidentiality focuses on information designated as confidential.
Think:
Classification
Access Restrictions
Encryption
Retention
Secure DisposalPart 7 — Privacy
Section titled “Part 7 — Privacy”Privacy addresses personal information and how it is:
Collected
Used
Retained
Disclosed
Disposedaccording to relevant commitments and criteria.
Part 8 — Security Is Foundational
Section titled “Part 8 — Security Is Foundational”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 CommitmentsPart 9 — Do Not Select Categories for Marketing
Section titled “Part 9 — Do Not Select Categories for Marketing”Weak approach:
Let's IncludeAll FiveBecause ItLooks BetterProfessional approach:
Customer Commitments +System Requirements +Risk ↓Relevant TrustServices CategoriesEvery additional category can introduce additional criteria, controls, evidence, and examination effort.
Part 10 — Example CloudNova Selection
Section titled “Part 10 — Example CloudNova Selection”Suppose CloudNova determines that its enterprise SaaS commitments require:
Security
Availability
ConfidentialityPrivacy 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.
Part 11 — SOC 2 Type I vs Type II
Section titled “Part 11 — SOC 2 Type I vs Type II”A common source of confusion is:
Type IvsType IIA Type I report addresses control design and implementation as of a specified date.
Conceptually:
Do AppropriateControls Existat This Pointin Time?A Type II report additionally considers operating effectiveness over a specified period.
Conceptually:
Did ThoseControls OperateEffectively Overthe Review Period?Part 12 — Readiness for Type II
Section titled “Part 12 — Readiness for Type II”For Type II readiness, you need more than:
Policy ExistsYou need controls that:
Are Designed ↓Are Implemented ↓Operate Consistently ↓Generate Evidence ↓Can Be TestedOver TimePart 13 — SOC 1 vs SOC 2
Section titled “Part 13 — SOC 1 vs SOC 2”SOC 1 focuses on controls relevant to:
User Entities'Internal ControlOver Financial ReportingSOC 2 focuses on controls relevant to the applicable:
Trust ServicesCriteriaDo not use the terms interchangeably.
Part 14 — Define the System
Section titled “Part 14 — Define the System”Before evaluating controls, define:
What SystemAre WeAssessing?This is one of the most important parts of readiness.
Part 15 — Define System Boundary
Section titled “Part 15 — Define System Boundary”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 SystemsPart 16 — Identify Supporting Components
Section titled “Part 16 — Identify Supporting Components”The system is not only technology.
Consider:
Infrastructure
Software
People
Procedures
DataPart 17 — Infrastructure
Section titled “Part 17 — Infrastructure”Examples:
AWS
Kubernetes
Networks
Compute
Storage
Databases
Load BalancersPart 18 — Software
Section titled “Part 18 — Software”Examples:
CloudNova Application
CI/CD Tooling
Security Platforms
Monitoring Platforms
Identity Platforms
Supporting SaaSPart 19 — People
Section titled “Part 19 — People”Include relevant:
Developers
SRE
Security
IT
Customer Support
Management
ContractorsPart 20 — Procedures
Section titled “Part 20 — Procedures”Examples:
Access Management
Change Management
Incident Response
Vulnerability Management
Backup
Recovery
Vendor ManagementPart 21 — Data
Section titled “Part 21 — Data”Identify:
Customer Data
Authentication Data
Application Data
Logs
Backups
Configuration Data
Support DataPart 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 PlatformsThese may be:
SubserviceOrganizationsdepending 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-Outor:
Inclusivefor 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:
CloudNovaUses AWS ↓AWS OperatesCertain Physicaland InfrastructureControlsCloudNova 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:
ComplementaryUser EntityControlsFor example:
CustomerMust ProtectAdministratorCredentialsPart 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
MonitoringPart 28 — Start With Risk
Section titled “Part 28 — Start With Risk”Control design should follow:
Service Commitments ↓System Requirements ↓Risk ↓Criteria ↓Controlsnot:
SOC 2 Checklist ↓Create RandomControlsPart 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 RiskThese risks can help determine appropriate controls.
Part 30 — Build Control Matrix
Section titled “Part 30 — Build Control Matrix”Create:
Control ID
Control Name
Control Objective
Control Description
Applicable Criterion
Risk
Control Owner
Frequency
Evidence
Control Type
StatusPart 31 — Example Control
Section titled “Part 31 — Example Control”Control ID:IAM-001
Control:Privileged MFA
Objective:Protect privilegedaccounts fromunauthorized access.
Owner:IAM Manager
Frequency:Continuous
Evidence:Identity configurationand account reportsPart 32 — One Control Can Support Multiple Criteria
Section titled “Part 32 — One Control Can Support Multiple Criteria”Avoid assuming:
One Criterion=One ControlAn enterprise control may support multiple requirements.
Example:
QuarterlyPrivileged Access Reviewmay support several security-related criteria.
Part 33 — Reuse Existing ISO Controls
Section titled “Part 33 — Reuse Existing ISO Controls”CloudNova already has controls from its ISMS.
Instead of:
ISO Controls+Separate SOC 2 Controlsbuild:
EnterpriseCommon Controls ↓ISO 27001Mapping +SOC 2MappingPart 34 — Common Control Framework
Section titled “Part 34 — Common Control Framework”Example:
Internal ControlIAM-001 ↓ISO Mapping ↓SOC 2 Mapping ↓NIST Mapping ↓Customer RequirementThis reduces duplicate control management.
Part 35 — Assess Control Design
Section titled “Part 35 — Assess Control Design”For every control ask:
Would This Control,If Performedas Designed,Address theRelevant Risk?Part 36 — Design Example
Section titled “Part 36 — Design Example”Risk:
Former EmployeeRetains AccessControl:
HR Emails ITWhen SomeoneLeavesThis may work.
But ask:
Is It Timely?
Is It Complete?
Who Tracks It?
What HappensIf Email Is Missed?
Can It Be Proven?Part 37 — Better Control Design
Section titled “Part 37 — Better Control Design”HR TerminationRecord Created ↓Automated Workflow ↓Identity AccessDisabled ↓Ticket Generated ↓Completion Verified ↓Exception EscalatedPart 38 — Assess Implementation
Section titled “Part 38 — Assess Implementation”A well-designed control is not useful if:
NobodyImplemented ItVerify:
Configuration
Procedure
Ownership
Workflow
EvidencePart 39 — Assess Operating Readiness
Section titled “Part 39 — Assess Operating Readiness”For Type II preparation, ask:
Has the ControlOperated ConsistentlyAcross the IntendedPeriod?Part 40 — Example
Section titled “Part 40 — Example”Control:
QuarterlyAccess ReviewEvidence:
Q1 ✓
Q2 ✓
Q3 Missing
Q4 ✓Conclusion:
Control Exists
Design MayBe Appropriate
OperationIs InconsistentPart 41 — Define Control Frequency
Section titled “Part 41 — Define Control Frequency”Controls may operate:
Continuous
Daily
Weekly
Monthly
Quarterly
Annually
Event-DrivenFrequency affects evidence expectations and sampling.
Part 42 — Identify Control Owners
Section titled “Part 42 — Identify Control Owners”Every control should answer:
Who IsAccountablefor This Control?Examples:
IAM→ Access Controls
Security Engineering→ Vulnerability Controls
SOC→ Monitoring
Engineering→ Change Controls
HR→ Personnel Controls
TPRM→ Vendor Controls
BCM→ Recovery ControlsPart 43 — Build Ownership Register
Section titled “Part 43 — Build Ownership Register”| 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 ↓EvidenceEvidence should be produced through normal control operation.
Part 45 — Evidence Examples
Section titled “Part 45 — Evidence Examples”Examples include:
Policies
System Configurations
System-Generated Reports
Tickets
Approvals
Logs
Access Reviews
Change Records
Incident Records
Training Records
Vendor Assessments
Recovery Tests
Meeting MinutesPart 46 — Evidence Quality
Section titled “Part 46 — Evidence Quality”Good evidence should be:
Relevant
Reliable
Complete
Accurate
Current
TraceablePart 47 — Evidence Hierarchy
Section titled “Part 47 — Evidence Hierarchy”Depending on the control, stronger evidence often includes:
System-GeneratedEvidencerather than relying solely on:
ManualScreenshotsScreenshots can still be useful, but they may require additional context and validation.
Part 48 — Build Evidence Request List
Section titled “Part 48 — Build Evidence Request List”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 |
Part 49 — Create Evidence Repository
Section titled “Part 49 — Create Evidence Repository”Suggested:
SOC2-Evidence│├── Governance├── Risk├── IAM├── Asset Management├── Change Management├── Vulnerability Management├── Logging├── Incident Response├── Vendor Management├── Business Continuity├── HR└── PrivacyPart 50 — Avoid Auditor-Specific Evidence Silos
Section titled “Part 50 — Avoid Auditor-Specific Evidence Silos”Weak:
ISO Evidence
SOC 2 Evidence
Customer EvidenceBetter:
EnterpriseControl Evidence ↓MultipleAssurance UsesPart 51 — Evaluate Governance Controls
Section titled “Part 51 — Evaluate Governance Controls”Review:
Security Governance
Roles & Responsibilities
Policies
Risk Management
Management Oversight
Control MonitoringPart 52 — Evaluate Access Controls
Section titled “Part 52 — Evaluate Access Controls”Review:
User Provisioning
Authentication
MFA
Privileged Access
Access Reviews
Termination
Service Accounts
Access ExceptionsPart 53 — Evaluate Asset Management
Section titled “Part 53 — Evaluate Asset Management”Review:
Asset Inventory
Ownership
Classification
Lifecycle
Cloud Resources
Endpoints
SoftwarePart 54 — Evaluate Change Management
Section titled “Part 54 — Evaluate Change Management”Review:
Change Request
Authorization
Testing
Approval
Deployment
Emergency Changes
RollbackPart 55 — Example Change Workflow
Section titled “Part 55 — Example Change Workflow”Code Change ↓Pull Request ↓Peer Review ↓Automated Testing ↓Approval ↓Deployment ↓LoggingPart 56 — Test Change Samples
Section titled “Part 56 — Test Change Samples”Select changes and verify:
Request
Approval
Testing
Reviewer
Deployment
Segregation
TraceabilityPart 57 — Evaluate Vulnerability Management
Section titled “Part 57 — Evaluate Vulnerability Management”Review:
Scanning
Prioritization
Remediation SLA
Exception Management
Validation
ReportingPart 58 — Example Evidence
Section titled “Part 58 — Example Evidence”Scanner Report
Critical Finding
Ticket
Assigned Owner
Remediation
Rescan
ClosurePart 59 — Evaluate Security Monitoring
Section titled “Part 59 — Evaluate Security Monitoring”Review:
Logging
SIEM
Alerting
Triage
Escalation
Incident Creation
RetentionPart 60 — Test Monitoring
Section titled “Part 60 — Test Monitoring”Select alerts and trace:
Security Event ↓Alert ↓Analyst Review ↓Disposition ↓Escalation ↓IncidentPart 61 — Evaluate Incident Response
Section titled “Part 61 — Evaluate Incident Response”Review:
Incident Policy
Response Plan
Roles
Detection
Escalation
Communication
Investigation
Recovery
Lessons LearnedPart 62 — Test Incident Samples
Section titled “Part 62 — Test Incident Samples”Verify:
Incident Record
Severity
Timeline
Actions
Communication
Closure
Lessons LearnedPart 63 — Evaluate Vendor Management
Section titled “Part 63 — Evaluate Vendor Management”Review:
Vendor Inventory
Risk Classification
Due Diligence
Security Assessment
Contract Requirements
Monitoring
Reassessment
TerminationPart 64 — Critical Vendors
Section titled “Part 64 — Critical Vendors”Focus on providers that could materially affect:
Security
Availability
Confidentiality
Privacy
ProcessingPart 65 — Evaluate Business Continuity
Section titled “Part 65 — Evaluate Business Continuity”If Availability is in scope, review:
Business Impact Analysis
Recovery Requirements
Backup
Redundancy
Disaster Recovery
Testing
Capacity
MonitoringPart 66 — Evaluate Backup Controls
Section titled “Part 66 — Evaluate Backup Controls”Determine:
What Is Backed Up?
How Often?
Where?
How Is It Protected?
Is Restore Tested?
Who Reviews Failures?Part 67 — Evaluate Recovery Testing
Section titled “Part 67 — Evaluate Recovery Testing”Evidence may include:
Test Plan
Participants
Scenario
Recovery Results
RTO Results
RPO Results
Failures
Lessons Learned
RemediationPart 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 DisposalPart 69 — Evaluate Privacy Controls
Section titled “Part 69 — Evaluate Privacy Controls”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
MonitoringThe exact assessment should follow the applicable Trust Services Criteria and organizational commitments.
Part 70 — Evaluate HR Controls
Section titled “Part 70 — Evaluate HR Controls”Review:
Background Screening
Security Agreements
Onboarding
Training
Role Changes
Termination
ConfidentialityPart 71 — Evaluate Security Awareness
Section titled “Part 71 — Evaluate Security Awareness”Evidence may include:
Training Content
Employee Population
Completion Records
Reminders
Exceptions
Phishing ExercisesPart 72 — Evaluate Logical Access
Section titled “Part 72 — Evaluate Logical Access”Trace:
Employee ↓Approved Role ↓Access Request ↓Approval ↓Provisioning ↓Periodic Review ↓Modification ↓TerminationPart 73 — Test Joiners
Section titled “Part 73 — Test Joiners”Select new employees.
Verify:
Request
Approval
Role
Access
Provisioning DatePart 74 — Test Movers
Section titled “Part 74 — Test Movers”Select employees who changed roles.
Verify:
Old Access
New Role
Required Access
Removed Access
ApprovalPart 75 — Test Leavers
Section titled “Part 75 — Test Leavers”Select terminated personnel.
Verify:
Termination Date
Notification
Account Disablement
Privileged Access
Tokens
DevicesPart 76 — Evaluate Exceptions
Section titled “Part 76 — Evaluate Exceptions”Controls may have exceptions.
Examples:
MFA Exception
Vulnerability Exception
Emergency Change
Access ExceptionEvery exception should have appropriate:
Justification
Approval
Risk Evaluation
Compensating Control
Expiration
ReviewPart 77 — Identify Readiness Gaps
Section titled “Part 77 — Identify Readiness Gaps”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 MonitoringPart 78 — Create Gap Register
Section titled “Part 78 — Create Gap Register”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 |
Part 79 — Write Strong Findings
Section titled “Part 79 — Write Strong Findings”Weak:
Access ReviewMissingBetter:
The quarterly privilegedaccess review was notcompleted during Q2.
Evidence was availablefor Q1 and Q3, butno evidence was availablefor Q2.Part 80 — Finding Structure
Section titled “Part 80 — Finding Structure”Use:
Criteria
Control
Condition
Evidence
Risk
RecommendationPart 81 — Root Cause
Section titled “Part 81 — Root Cause”Do not stop at:
ControlFailedAsk:
Why DidIt Fail?Part 82 — Example Root Cause
Section titled “Part 82 — Example Root Cause”Gap:
Vendor ReviewsOverdueWhy?
No ReminderWhy?
No CentralReview CalendarWhy?
Vendor GovernanceNot IntegratedInto GRC WorkflowPart 83 — Remediation
Section titled “Part 83 — Remediation”Better action:
Centralize Vendor Inventory ↓Assign Risk Tier ↓Define Review Frequency ↓Automate Reminder ↓Escalate Overdue Reviews ↓Track EvidencePart 84 — Build Remediation Register
Section titled “Part 84 — Build Remediation Register”Record:
Gap ID
Action
Owner
Priority
Dependencies
Target Date
Expected Evidence
Status
Retest ResultPart 85 — Do Not Close Gaps Too Early
Section titled “Part 85 — Do Not Close Gaps Too Early”Do not close because:
PolicyCreatedValidate:
Control Designed ↓Implemented ↓Operated ↓Evidence Generated ↓RetestedPart 86 — Prepare for Observation Period
Section titled “Part 86 — Prepare for Observation Period”For a Type II examination, operating history matters.
A control introduced:
Yesterdaycannot demonstrate months of prior operation.
Therefore readiness planning must consider:
Control Implementation ↓Stabilization ↓Evidence Generation ↓Operating Period ↓ExaminationThe exact examination period and expectations should be coordinated with the CPA firm performing the engagement.
Part 87 — Create Control Calendar
Section titled “Part 87 — Create Control Calendar”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 |
Part 88 — Evidence Calendar
Section titled “Part 88 — Evidence Calendar”Track:
Control
Expected Date
Evidence Due
Owner
Collected
Reviewed
ExceptionPart 89 — Continuous Evidence Readiness
Section titled “Part 89 — Continuous Evidence Readiness”Mature organizations move from:
Auditor RequestsEvidence ↓Everyone Searchesfor Filesto:
Control Operates ↓Evidence Generated ↓Evidence Stored ↓Evidence Validated ↓Audit ReadyPart 90 — Build Readiness Dashboard
Section titled “Part 90 — Build Readiness Dashboard”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 2Values 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 Ready92%without explaining:
Which ControlsAre Missing?
Which ControlsFailed?
Which EvidenceIs Missing?
Which GapsCould Affectthe Examination?Part 92 — Identify Readiness Blockers
Section titled “Part 92 — Identify Readiness Blockers”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 RecoveryActual significance depends on scope, criteria, control design, and the auditor’s evaluation.
Part 93 — Create Readiness Heat Map
Section titled “Part 93 — Create Readiness Heat Map”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 |
Part 94 — Prepare Management Report
Section titled “Part 94 — Prepare Management Report”Management wants to know:
Are We Ready?
What Arethe Biggest Gaps?
What CouldDelay the Examination?
What MustBe Fixed?
Who Ownsthe Work?
What ResourcesAre Required?
When Can WeBegin theOperating Period?Part 95 — Executive Summary Structure
Section titled “Part 95 — Executive Summary Structure”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 DecisionsPart 96 — Example Executive Narrative
Section titled “Part 96 — Example Executive Narrative”CloudNova has establisheda substantial securitycontrol environment throughits existing ISMS.
Many existing controls cansupport SOC 2 requirements.
Readiness gaps remain inprivileged access reviews,vendor monitoring,recovery testing, andevidence consistency.
These gaps should beremediated and operatingevidence established beforeprogressing into the intendedType II examination period.Part 97 — Reuse ISO 27001 Work
Section titled “Part 97 — Reuse ISO 27001 Work”Your previous project created:
ISO 27001Control EnvironmentNow map it:
Enterprise Control ↓ISO 27001 +SOC 2Part 98 — Example Cross-Mapping
Section titled “Part 98 — Example Cross-Mapping”Risk:Unauthorized Access ↓Control:IAM-001 MFA ↓ISO Mapping ↓SOC 2 Mapping ↓Evidence:Identity ReportPart 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 Frameworksnot:
ISO Control
SOC Control
Customer Control
NIST Controlall independently managed.
Part 100 — Build Common Control Library
Section titled “Part 100 — Build Common Control Library”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 ProtectionPart 101 — Control ID Example
Section titled “Part 101 — Control ID Example”IAM-001Privileged MFA
IAM-002Quarterly PrivilegedAccess Review
IAM-003User Termination
VM-001Vulnerability Scanning
VM-002Critical VulnerabilityRemediationPart 102 — Build Traceability
Section titled “Part 102 — Build Traceability”Maintain:
Risk ↓Control ↓SOC 2 Criterion ↓Owner ↓Evidence ↓Testing ↓Finding ↓RemediationPart 103 — Create Traceability Matrix
Section titled “Part 103 — Create Traceability Matrix”| 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.
Part 104 — Establish Evidence Retention
Section titled “Part 104 — Establish Evidence Retention”Determine:
What EvidenceMust Be Retained?
For How Long?
Where?
Who Can Access It?
How Is IntegrityProtected?Retention should reflect examination needs and applicable business, legal, contractual, and regulatory requirements.
Part 105 — Prepare Teams
Section titled “Part 105 — Prepare Teams”Control owners should understand:
What ControlDo I Own?
How OftenDoes It Operate?
What EvidenceMust I Produce?
Where IsEvidence Stored?
What HappensIf It Fails?
Who MustI 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
PrivacyWalk through:
Control ↓Procedure ↓Evidence ↓Exceptions ↓TestingPart 107 — Perform Mock Evidence Request
Section titled “Part 107 — Perform Mock Evidence Request”Simulate:
Auditor RequestsQ2 Access ReviewMeasure:
Can We Find It?
Is It Complete?
Is It Approved?
Does It Matchthe Population?
Can We Explain It?Part 108 — Perform Mock Sampling
Section titled “Part 108 — Perform Mock Sampling”For example, select:
10 Joiners
10 Leavers
10 Changes
5 Incidents
5 VendorsSample sizes here are for training only.
Actual testing and sample selection are determined by the auditor based on the engagement.
Part 109 — Identify Evidence Failures
Section titled “Part 109 — Identify Evidence Failures”Typical problems:
Missing Approval
Wrong Date
Incomplete Population
No Owner
No Timestamp
Screenshot Without Context
Evidence Storedin Personal Folder
Ticket ClosedWithout ValidationPart 110 — Remediate Evidence Problems
Section titled “Part 110 — Remediate Evidence Problems”Move toward:
System-Generated
Centralized
Repeatable
Traceable
Reviewableevidence.
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 ComplianceAutomation Tool ↓AssumeSOC 2 ReadyA tool may automate:
Evidence Collection
Monitoring
Control Trackingbut it cannot replace:
Governance
Risk Decisions
Control Design
Ownership
Operational DisciplinePart 113 — Common Mistake: Copying Controls
Section titled “Part 113 — Common Mistake: Copying Controls”Do not simply copy:
Generic SOC 2Control ListControls must reflect:
CloudNova's
Systems
Risks
Processes
CommitmentsPart 114 — Common Mistake: Policies Without Evidence
Section titled “Part 114 — Common Mistake: Policies Without Evidence”Policy:Access ReviewedQuarterlydoes not prove:
Quarterly ReviewsActually HappenedPart 115 — Common Mistake: Evidence Created for Audit
Section titled “Part 115 — Common Mistake: Evidence Created for Audit”Weak:
Audit Coming ↓Create EvidenceBetter:
Control Operation ↓Evidence GeneratedAutomaticallyPart 116 — Common Mistake: Ignoring Exceptions
Section titled “Part 116 — Common Mistake: Ignoring Exceptions”Auditors may discover:
Control Worksfor 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 OwnsThis Control?is:
Security Teamownership may be too vague.
Prefer:
Named Role
Defined AccountabilityPart 118 — Common Mistake: Over-Scoping
Section titled “Part 118 — Common Mistake: Over-Scoping”Including unnecessary systems can create:
More Controls
More Evidence
More Testing
More Exceptions
More CostDefine 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
Communicationproviders.
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:
AttestationReportnot a traditional certification like ISO/IEC 27001 certification.
Use terminology carefully.
Part 122 — SOC 2 Readiness Maturity
Section titled “Part 122 — SOC 2 Readiness Maturity”Level 1 — Ad Hoc
Section titled “Level 1 — Ad Hoc”Controls ExistInformallyLevel 2 — Defined
Section titled “Level 2 — Defined”ControlsDocumentedLevel 3 — Implemented
Section titled “Level 3 — Implemented”ControlsOperatingLevel 4 — Evidence Ready
Section titled “Level 4 — Evidence Ready”ConsistentEvidenceAvailableLevel 5 — Assurance Ready
Section titled “Level 5 — Assurance Ready”Controls
Evidence
Monitoring
Exceptions
Testing
Governanceoperate as an integrated assurance system.
Part 123 — Future-State CloudNova
Section titled “Part 123 — Future-State CloudNova”Move from:
Compliance Request ↓Find Evidence ↓Fix Problem ↓Respondto:
Enterprise Controls ↓Continuous Operation ↓Evidence Generation ↓Control Monitoring ↓Exception Management ↓Continuous AssurancePractical Assignment
Section titled “Practical Assignment”Perform the SOC 2 readiness review for CloudNova.
Task 1 — Define System Boundary
Section titled “Task 1 — Define System Boundary”Document:
Infrastructure
Software
People
Procedures
Data
Third PartiesTask 2 — Select Trust Services Categories
Section titled “Task 2 — Select Trust Services Categories”Determine whether CloudNova requires:
Security
Availability
Processing Integrity
Confidentiality
Privacyand document the rationale.
Task 3 — Build System Inventory
Section titled “Task 3 — Build System Inventory”Identify at least:
20 SystemComponentsTask 4 — Build Control Matrix
Section titled “Task 4 — Build Control Matrix”Create at least:
30 EnterpriseControlsacross:
Governance
Risk
IAM
Asset Management
Change Management
Vulnerability Management
Monitoring
Incident Response
Vendor Risk
BCM
HR
Data ProtectionTask 5 — Assign Control Owners
Section titled “Task 5 — Assign Control Owners”Every control must have:
Accountable Owner
Operator
Evidence OwnerTask 6 — Create Evidence Request List
Section titled “Task 6 — Create Evidence Request List”Identify at least:
30 EvidenceArtifactsTask 7 — Assess Control Design
Section titled “Task 7 — Assess Control Design”Determine:
Effective Design
Partial Design
Ineffective Designusing a documented internal readiness methodology.
Task 8 — Assess Implementation
Section titled “Task 8 — Assess Implementation”Determine whether each control is:
Implemented
Partially Implemented
Not ImplementedTask 9 — Assess Operating Readiness
Section titled “Task 9 — Assess Operating Readiness”For recurring controls, inspect representative evidence across the relevant period.
Task 10 — Perform Mock Sampling
Section titled “Task 10 — Perform Mock Sampling”Sample:
Joiners
Movers
Leavers
Changes
Incidents
Vulnerabilities
VendorsTask 11 — Create Gap Register
Section titled “Task 11 — Create Gap Register”Identify at least:
15 RealisticReadiness GapsTask 12 — Root Cause Analysis
Section titled “Task 12 — Root Cause Analysis”Perform root-cause analysis for at least:
5 High-PriorityGapsTask 13 — Build Remediation Plan
Section titled “Task 13 — Build Remediation Plan”For each high-priority gap define:
Action
Owner
Target Date
Evidence
Success CriteriaTask 14 — Build Readiness Dashboard
Section titled “Task 14 — Build Readiness Dashboard”Summarize:
Control Status
Evidence Status
Gap Severity
Remediation
Readiness BlockersTask 15 — Prepare Management Report
Section titled “Task 15 — Prepare Management Report”Answer:
Are We Ready?
What Is Missing?
What CouldDelay Us?
What MustManagement Decide?
When Can WeMove Forward?Final Validation Checklist
Section titled “Final Validation Checklist”-
service commitments understood.
-
system boundary defined.
-
infrastructure identified.
-
software identified.
-
people identified.
-
procedures identified.
-
data identified.
-
relevant third parties identified.
Trust Services Criteria
Section titled “Trust Services Criteria”-
Security included.
-
additional categories evaluated.
-
selection rationale documented.
-
applicable criteria identified.
-
internal controls mapped.
Controls
Section titled “Controls”-
controls defined.
-
control objectives documented.
-
owners assigned.
-
frequencies established.
-
design evaluated.
-
implementation validated.
-
operation reviewed.
Evidence
Section titled “Evidence”-
evidence requirements identified.
-
evidence owners assigned.
-
evidence collected.
-
evidence quality reviewed.
-
repository established.
-
traceability maintained.
Testing
Section titled “Testing”-
populations identified.
-
representative samples selected.
-
control operation evaluated.
-
exceptions documented.
-
failed samples investigated.
-
results recorded.
Third Parties
Section titled “Third Parties”-
subservice organizations identified.
-
relevant responsibilities understood.
-
vendor controls assessed.
-
customer responsibilities considered where relevant.
Findings
Section titled “Findings”-
gaps clearly documented.
-
evidence referenced.
-
risk identified.
-
root causes considered.
-
recommendations developed.
-
priorities assigned.
Remediation
Section titled “Remediation”-
owners assigned.
-
target dates established.
-
evidence requirements defined.
-
success criteria established.
-
remediation retesting planned.
Readiness
Section titled “Readiness”-
readiness blockers identified.
-
control calendar established.
-
evidence calendar established.
-
operating period considered.
-
management report completed.
-
next steps agreed.
Expected Project Folder
Section titled “Expected Project Folder”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 RoadmapSuccess Criteria
Section titled “Success Criteria”You successfully complete this project when you can move from:
CustomerAssurance Requirement ↓SOC 2 Scope ↓System Boundary ↓Trust Services Criteria ↓Enterprise Risk ↓Controls ↓Ownership ↓Operation ↓Evidence ↓Testing ↓Gaps ↓Remediation ↓Readinessand answer:
What SystemIs In Scope?
Which Trust ServicesCategories Apply?
Which RisksMatter?
Which ControlsAddress Them?
Who OwnsEach Control?
Are ControlsDesigned Appropriately?
Are TheyImplemented?
Do TheyOperate Consistently?
Can WeProduce Evidence?
What ExceptionsExist?
Which GapsCould Affect Readiness?
What MustBe Remediated?
Are We Readyto Proceed?Career Connection
Section titled “Career Connection”This project reflects work performed by:
GRC Analysts
SOC 2 ReadinessConsultants
Security ComplianceAnalysts
Security AssuranceProfessionals
Internal Auditors
GRC Consultants
Security GovernanceManagersA beginner may approach SOC 2 as:
Checklist ↓Collect Evidence ↓Pass AuditA professional approaches it as:
Business Commitments ↓System ↓Risk ↓Criteria ↓Controls ↓Ownership ↓Evidence ↓Operating Effectiveness ↓Independent AssuranceThe goal is not simply:
Get aSOC 2 ReportThe goal is to build a control environment capable of providing:
Consistent
Repeatable
Evidence-Based
IndependentAssuranceWhat’s Next?
Section titled “What’s Next?”➡️ Next: 05 — Conduct a PCI-DSS Assessment
You have now completed:
Enterprise Risk Assessment ↓Build an ISMS ↓ISO 27001 Gap Assessment ↓SOC 2 Readiness ReviewThe next project moves into a more prescriptive compliance environment:
Payment CardSecurityYou will learn how to determine:
Where CardholderData Exists
How Payment DataFlows
What SystemsAre In Scope
How ScopeCan Be Reduced
Which PCI DSSRequirements Apply
What ControlsAre Required
What EvidenceDemonstrates Compliance
Where ComplianceGaps ExistYou 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