When organizations pursue SOC 2 (System and Organization Controls 2) compliance, they often wonder whether they need to adhere to all five Trust Service Criteria (TSC) or if they can focus on just one. The answer is yes, you can achieve SOC 2 compliance with only one trust service criterion, such as Confidentiality—but there are important considerations to keep in mind.
Understanding SOC 2 and Trust Service Criteria
SOC 2 is a framework developed by the American Institute of Certified Public Accountants (AICPA) that evaluates an organization’s ability to secure, process, and protect customer data. The framework consists of five Trust Service Criteria (TSC):
- Security (Common Criteria) – Protecting information and systems from unauthorized access and threats.
- Availability – Ensuring that systems and data are available for operation and use as committed.
- Processing Integrity – Ensuring that system processing is complete, valid, accurate, and timely.
- Confidentiality – Protecting sensitive data from unauthorized disclosure.
- Privacy – Governing the collection, use, and disclosure of personal information.
While the Security criterion is always required in a SOC 2 assessment, organizations can choose additional criteria based on their specific business needs. If your primary concern is Confidentiality, you can focus your SOC 2 compliance efforts on this area.
Achieving SOC 2 Compliance with Only Confidentiality
If an organization’s primary objective is to ensure the confidentiality of sensitive data, it can achieve SOC 2 compliance with only the Security and Confidentiality criteria. Here’s how:
1. Define the Scope of Your SOC 2 Audit
- Determine which systems, applications, and data are in scope for confidentiality.
- Identify the types of confidential information you handle (e.g., financial data, intellectual property, client records).
2. Implement Controls Aligned with Security and Confidentiality
- Access Controls: Restrict access to confidential data using authentication mechanisms such as multi-factor authentication (MFA) and role-based access controls (RBAC).
- Encryption: Ensure data is encrypted at rest and in transit to prevent unauthorized access.
- Data Retention and Disposal: Define policies for retaining and securely disposing of confidential information.
- Third-Party Risk Management: Ensure that vendors and third parties handling confidential data adhere to security standards.
3. Conduct a Readiness Assessment
- A SOC 2 readiness assessment helps identify gaps in your existing controls before the official audit.
- Review policies, procedures, and system configurations to ensure they align with SOC 2 requirements.
4. Work with a SOC 2 Auditor
- Engage a Certified Public Accountant (CPA) firm with expertise in SOC 2 audits.
- The auditor will assess your controls related to Security and Confidentiality and provide a SOC 2 Type I or Type II report.
5. Maintain Continuous Compliance
- SOC 2 compliance is not a one-time event. Organizations must maintain ongoing monitoring, employee training, and periodic reviews to ensure continued adherence to confidentiality controls.
Key Benefits of SOC 2 Compliance for Confidentiality
- Enhanced Trust with Clients: Demonstrates a commitment to protecting confidential information.
- Competitive Advantage: Helps differentiate your organization in industries where data confidentiality is a priority.
- Regulatory Alignment: Supports compliance with data protection regulations such as GDPR, HIPAA, and CCPA.
Final Thoughts
Achieving SOC 2 compliance with only Confidentiality as an additional trust service criterion is entirely possible. However, organizations must still meet the mandatory Security criteria and establish robust controls to protect confidential data effectively. If confidentiality is a major concern for your business, a SOC 2 report focused on Security and Confidentiality can provide assurance to stakeholders and help you stand out in the market.
Are you considering SOC 2 compliance for Confidentiality? Reach out to cybersecurity experts to start your journey today!