Need to get SOC 2 compliant?
You need to know how to implement the five TSCs.
SOC 2 Trust Services Criteria (TSC) are the backbone of ensuring your organization’s systems and data are secure, available, and reliable.
Without a clear understanding of the five principles, you risk operational inefficiencies, failed audits, and losing opportunities to close major deals with enterprise clients.
In this guide, we’ll break down each criterion, explain its importance, and provide actionable insights on effectively implementing and maintaining compliance with the SOC 2 TSCs.
What is SOC 2 compliance?
SOC 2 compliance is a cybersecurity framework designed to confirm that service providers are securely managing data to protect the privacy and interests of their clients.
Why do companies get SOC 2 compliant?
Because it builds trust with clients and stakeholders by verifying that the business follows industry-recognized data security standards.
Any organization that handles, stores, or processes customer data, especially cloud-based service providers, should pursue SOC 2 compliance.
There are many consequences of skipping SOC 2 compliance, but one key risk is the potential theft of your customers’ sensitive data — ranging from emails to credit card details.
Neither businesses nor their customers want to deal with that tragedy.
Did you know: The expenses associated with business disruption, productivity loss, revenue decline, and regulatory fines are 2.71 times higher than the cost of compliance, according to a study done by Ponemon Institute.
What are the SOC 2 Trust Services Criteria?
The SOC 2 Trust Services Criteria (TSC) are a set of five principles — Security, Availability, Processing Integrity, Confidentiality, and Privacy — that define the controls organizations must implement to protect customer data.
These five TSCs serve as the foundation for SOC 2 audits, confirming that an organization's systems are secure, reliable, and capable of protecting sensitive data.
While the Security criterion is mandatory for all SOC 2 audits, the other four are optional and should be selected based on the organization's services and customer requirements.
Below, we’ll break down each category in detail, starting with Security.
Security
The Security criterion evaluates whether systems and data are protected against unauthorized access, disclosure, and damage.
Let’s take a closer look at the Security criterion controls:
- Control Environment: Establishes a security-focused culture and sets the tone for oversight, accountability, and ethical behavior.
- Communication and Information: Ensures clear communication of security roles, responsibilities, and procedures within and outside the organization.
- Risk Assessment: Identifies and evaluates security risks to prevent breaches and vulnerabilities.
- Monitoring Activities: Continuously tracks and evaluates security controls to verify effectiveness.
- Control Activities: Implements policies and technologies to mitigate risks and prevent unauthorized actions.
- Logical and Physical Access Controls: Restricts physical and digital access to sensitive systems and information.
- System Operations: Monitors system performance and swiftly responds to security incidents.
- Change Management: Controls system updates and changes to prevent unauthorized alterations.
- Risk Mitigation: Reduces risks arising from third-party partnerships and external threats.
Every organization undergoing a SOC 2 audit must implement Security controls, regardless of its industry or size.
Availability
The Availability criterion assures that systems and data remain accessible and functional for authorized users when needed.
Here’s a breakdown of the Availability criterion controls:
- Capacity Management: Monitors and adjusts capacity to handle system demands without disruptions.
- Environmental Protection: Safeguards systems against physical and environmental threats.
- Backup and Recovery Plans: Establishes regular backups and a robust disaster recovery strategy.
- System Testing: Validates the effectiveness of backup and recovery procedures through regular testing.
Companies offering services where uptime and reliability are critical, such as cloud storage providers or SaaS platforms, should implement these controls.
Processing Integrity
The Processing Integrity criterion establishes whether systems are processing data accurately, completely, and reliably or not.
An overview of the Processing Integrity criterion controls:
- Quality Information Policies: Validates the data used in processing is reliable and accurate.
- System Input Controls: Verifies the accuracy and completeness of data entered into systems.
- System Processing Controls: Confirms that data is processed correctly without errors or inconsistencies.
- System Output Controls: Guarantees that processed data outputs are accurate and delivered on time.
- Data Storage Policies: Keeps an eye on how data is handled, transformed, and stored after processing.
Those involved in transaction processing, financial reporting, or any activity requiring accurate data manipulation should prioritize these controls.
Confidentiality
The Confidentiality criterion makes sure that sensitive data is accessible only to authorized individuals and protected from unauthorized access or misuse.
What are the Confidentiality criterion controls?
- Confidential Data Identification: Clearly defines and categorizes confidential information.
- Access Controls: Restricts access to confidential data based on user roles and responsibilities.
- Secure Disposal Policies: Guarantees proper and secure disposal of confidential data.
Businesses handling intellectual property, financial data, or trade secrets should implement confidentiality controls.
Privacy
The Privacy criterion focuses on protecting personal data, making certain it is collected, processed, and disposed of responsibly.
Here's a closer look at the Privacy criterion controls:
- Notice and Communication: Notifies individuals about data collection and privacy policies.
- Choice and Consent: Provides users with control over how their data is collected and used.
- Data Collection Policies: Limits data collection to only what is necessary for business purposes.
- Use, Retention, and Disposal Policies: Ensures secure storage, responsible use, and timely disposal of personal data.
- Access Controls: Allows individuals to review and edit their personal information.
- Disclosure and Notification: Notifies users of breaches or unauthorized data disclosures.
- Data Quality Standards: Maintains accurate, up-to-date, and complete personal data.
- Monitoring and Enforcement: Tracks privacy compliance and addresses privacy-related concerns effectively.
Any organization collecting or handling personally identifiable information (PII) should implement these controls.
PS: If you want to get a deeper understanding of the SOC 2 controls, we’d recommend you to read our blog: SOC 2 Controls: Your Roadmap to Compliance.
Overview of the COSO Framework
Let’s take a look at what the COSO framework is, its key principles, and how it aligns with the SOC 2 Trust Services Criteria to create an effective compliance strategy.
What is the COSO framework and what are its core principles?
The COSO (Committee of Sponsoring Organizations of the Treadway Commission) framework is a globally recognized model for designing, implementing, and evaluating internal controls within an organization.
It’s built around five core components of 17 principles total. Here’s a breakdown of each component:
The framework helps organizations establish a structured approach to managing operational, compliance, and financial risks while improving overall organizational effectiveness.
How does the COSO framework align with the SOC 2 TSC?
The COSO framework provides the structural foundation for the SOC 2 Trust Services Criteria by facilitating alignment between internal control objectives and SOC 2 compliance requirements.
For example, when implementing the Availability TSC, organizations use the COSO principle of Monitoring Activities to regularly test disaster recovery protocols and validate if systems remain resilient under pressure.
Together, the COSO framework and the SOC 2 TSC create a comprehensive approach to risk management, ensuring that controls are not only implemented but also evaluated and optimized regularly.
Now that we have a firm understanding of what the SOC 2 TSCs are about, let’s look at the best way to implement them.
How do you effectively implement the SOC 2 TSC?
Effectively implementing the SOC 2 TSCs requires a clear understanding of your organization’s objectives, identifying and implementing relevant controls, and maintaining ongoing monitoring and evaluation systems.
Here are the steps you need to take to define your scope, establish a strong control environment, and evaluate control effectiveness:
Define your SOC 2 Scope
Defining the scope makes sure that your organization focuses resources on controls and systems most relevant to its operations and audit objectives.
Without a well-defined scope, you risk wasting resources on unnecessary controls or overlooking critical systems, increasing your chances of audit failure.
Step-by-step guide to defining the scope effectively:
- Identify business objectives: Determine your primary compliance goals (e.g., securing client data, enabling faster audits).
- Map relevant systems: Identify all systems, applications, and infrastructure related to data processing, storage, and access.
- Assess data flow: Understand how data moves through your systems, including entry points, storage locations, and exit points.
- Determine relevant TSCs: Decide which TSCs (Security, Availability, Processing Integrity, Confidentiality, Privacy) are applicable based on your services and customer requirements.
- Set boundaries: Clearly outline what falls inside and outside the audit scope (e.g., third-party tools, physical access controls).
Pro Tip: Regularly revisit your scope as your organization grows or adopts new technologies. Uncontrolled scope expansion can lead to overlooked vulnerabilities or misaligned controls.
Establish a reliable control environment
A strong control environment sets the foundation for all other compliance efforts. Without it, security policies lack enforcement, and controls become inconsistent.
Step-by-step guide to establishing a reliable control environment:
- Define security policies: Create clear and enforceable policies governing data security, risk management, and internal controls.
- Assign roles and responsibilities: Designate control owners for critical tasks such as access management, incident response, and compliance monitoring.
- Employee training: Educate staff on security responsibilities, data privacy practices, and compliance protocols.
- Documentation and communication: Maintain thorough documentation of policies, procedures, and audit logs for transparency.
NB! Your control environment isn’t static. Regularly evaluate leadership roles, update policies, and verify that new hires are properly trained on compliance requirements.
Evaluate control effectiveness
Regular evaluation of control effectiveness confirm that security measures function as intended and remain aligned with evolving threats and organizational changes.
Without regular evaluations, systems can become outdated or ineffective, creating security gaps that hackers can easily exploit.
Step-by-step guide to evaluating control effectiveness:
- Set clear metrics: Define Key Performance Indicators (KPIs) and benchmarks for control effectiveness.
- Perform regular audits: Schedule periodic audits to assess controls across all TSCs.
- Test controls: Conduct control testing (e.g., penetration tests, system vulnerability scans) to identify weaknesses.
- Review incident reports: Analyze past security incidents to identify recurring issues or ineffective controls.
- Implement corrective actions: Address identified deficiencies promptly and document remediation steps.
Pro Tip: Use a compliance automation tool, like EasyAudit, to automate control evaluations, detect vulnerabilities instantly, and guarantee ongoing compliance effortlessly.
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The result?
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How do you maintain compliance with the SOC 2 TSC?
Maintaining compliance with the SOC 2 TSCs involves continuous monitoring, regular updates to security controls, and efficient evidence collection processes.
Below, we’ll take a closer look at the three critical practices for maintaining compliance, so that you have maximum clarity on what needs to be done.
Implement continuous monitoring systems
Continuous monitoring double-checks that security controls remain effective over time by proactively identifying vulnerabilities, misconfigurations, or anomalies.
Without it, organizations risk compliance gaps, unnoticed breaches, and audit failures.
How to implement continuous monitoring systems:
- Identify key metrics: Define critical compliance indicators, such as access logs, configuration changes, and incident alerts.
- Deploy monitoring tools: Use automated monitoring tools to track system activity, detect anomalies, and flag vulnerabilities in real-time.
- Set alerts: Configure alerts for high-risk activities, such as unauthorized access attempts or failed system updates.
- Schedule regular audits: Perform scheduled audits to verify monitoring tool performance and coverage.
- Document findings: Maintain logs and reports from monitoring tools to demonstrate compliance during audits.
Streamline evidence collection process
Efficient evidence collection processes simplify the audit process and reduce compliance fatigue.
How to streamline evidence collection:
- Centralize documentation: Store compliance evidence in a single, secure, and accessible repository.
- Automate evidence gathering: Use a compliance automation tool (e.g., EasyAudit) to collect evidence directly from systems and applications.
- Establish naming conventions: Use consistent naming conventions and version controls for all compliance documents.
- Assign ownership: Designate control owners responsible for evidence collection in their respective domains.
- Conduct mock audits: Regularly simulate audit scenarios to ensure evidence is audit-ready and accessible.
Regularly update and optimize security controls
In 2024, 80% of organizations planned to increase their cybersecurity budgets, according to a Gartner survey.
Why?
Data security threats are evolving constantly.
What does this mean for your security controls?
They become obsolete if you don’t update and optimize them.
Regular updates make certain your organization stays ahead of vulnerabilities and maintains compliance with current standards.
How to regularly update and optimize security controls:
- Perform risk assessments: Regularly assess risks associated with your infrastructure, systems, and third-party vendors.
- Update policies and procedures: Align internal policies with emerging threats and regulatory changes.
- Patch management: Regularly apply software patches and updates to address known vulnerabilities.
- Optimize system configurations: Fine-tune security settings to minimize exposure to threats.
- Train employees: Provide regular training on updated security controls and compliance protocols.
Pro Tip: Schedule quarterly reviews of your controls, even if no major changes have occurred. Small updates can prevent larger vulnerabilities from developing over time.
What are the common pitfalls in SOC 2 Trust Services Criteria compliance?
SOC 2 compliance is a rigorous process, and organizations often encounter challenges along the way. Common pitfalls include resource allocation issues, documentation inconsistencies, and poor control testing preparation.
Understanding these pitfalls and taking proactive measures can prevent delays, failed audits, and compliance fatigue. Let’s break down each pitfall and how to avoid it.
Misallocating resources
One of the most common pitfalls in SOC 2 compliance is misallocating resources — either underestimating the time and personnel needed or assigning responsibilities to unqualified team members. This can result in missed deadlines, incomplete controls, and failed audits.
How to avoid misallocating resources:
- Assign dedicated roles: Designate experienced compliance officers and security specialists to lead SOC 2 initiatives.
- Plan realistically: Set achievable timelines and milestones for each phase of the compliance process.
Inadequate documentation
Incomplete, outdated, or poorly organized documentation is one of the top reasons organizations fail SOC 2 audits.
Auditors rely heavily on documentation to validate compliance, and inconsistencies can cause audit failures.
How to document properly:
- Centralize documentation: Store all compliance-related documents in a secure, organized repository.
- Create version histories: Maintain version control and document updates to track changes over time.
- Align with TSCs: Make sure all documentation maps directly to the relevant Trust Services Criteria controls.
- Regular reviews: Periodically review and update compliance documents to align with operational changes.
Poor control testing preparation
Control testing is a critical component of SOC 2 audits, and poor preparation can result in failed tests, increased remediation timelines, and repeated audits.
This often happens when controls are inadequately tested internally before the official audit.
How to prepare for control testing:
- Develop test scenarios: Create test cases that simulate real-world threats and compliance checks.
- Assign ownership: Clearly define roles and responsibilities for control testing across teams.
- Document test results: Maintain clear records of control testing outcomes, including successes and failures.
- Address findings promptly: Immediately address weaknesses identified during internal tests.
Now, what is the best way to implement all of this?
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FAQs
Are all five SOC 2 Trust Services Criteria (TSC) mandatory for compliance?
No, only the Security criterion is mandatory for every SOC 2 audit. The other four are optional and should be included based on your organization’s services and customer requirements.
Is there an order in which organizations should implement the TSCs?
While Security is mandatory and serves as the foundation, the order of implementing the other TSCs solely depends on business priorities and compliance goals.
For instance, a company handling sensitive customer data might focus on Confidentiality and Privacy first, before implementing the other criteria (if they need to).
Can you add more TSCs after the initial SOC 2 audit?
Yes, organizations often start with the Security criterion during their first audit and add other criteria, such as Privacy or Processing Integrity, in subsequent audits as their compliance maturity grows.