Define your SOC 2 audit scope

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Define your SOC 2 audit scope

Audit scope definition is always part of any audit. The scope sets the boundaries of the audit and identifies the object in focus.

The object can include the people, data, system, or product in review. The scope definition allows the auditors to focus on an aspect of the organization rather than the whole. This is why it is important to clearly define the scope of review for your given audit.

Determining your SOC 2 audit scope requires your organization to specify the product, the data, the systems, vendors, Trust Service Criteria (TSC), and type of scope.

Read below for guidance on how to determine each scope item. A table listing each item is provided below to use as a template for this exercise.

Product(s) in scope

For a Software as a Service (SaaS) provider, the scope is typically the software application(s) offered to clients. Some organizations have multiple products, and it is important to define for your SOC 2 what product is in focus and what product isn’t.

Data in scope

In order to identify the data in scope, the ideal step is to focus on the type of data and people that flow through the product or service identified. For a (SaaS) provider, it’s typically all the data held in it (i.e., customer data, etc.) and the people that support it, such as vendors and employees.

Systems in scope

To identify all your systems in scope, take an inventory of all the various systems and internal controls that are critical to delivering your service or product in scope. This could include email and Slack; the key is to focus on the systems and tools that are essential to delivering your service/product. Production systems have a direct impact on your product or service in lieu of non-production systems.

For HR systems, focus on systems that manage employee onboarding and training processes. Everything else, such as time off requests and benefits, is out of scope since it is not critical to delivering a service or product.

For a SaaS provider, all the infrastructure that hosts it and the procedures that support it, such as AWS, Github, JIRA, etc.

Vendors in scope

In order to identify the vendors in scope, focus on the critical vendors, such as cloud hosting production-related companies used to support the product or service in scope.

Trust Service Criteria (TSC) in scope

In order to identify which of the TSCs to include, it is important to understand what they are. As a reminder (and previously described in the SOC 2 Overview and guides), SOC 2 is composed of five TSCs for evaluating and reporting on the robustness of an organization’s systems and policies.

SOC 2

The Trust Service Criteria (TSC) are the foundation of SOC 2 audits and provide the framework for evaluating these controls. Let’s delve into each of the Trust Service Criteria in scope:

  1. Security (Required): This criterion assesses whether the system is protected against unauthorized access (both physical and logical), ensuring that data is safeguarded against potential breaches, theft, or damage. It includes controls related to network security, user authentication, data encryption, and incident response.
  2. Availability (Optional): Availability measures the system’s uptime and accessibility, ensuring that it remains operational and accessible to users as agreed upon in service level agreements (SLAs). This criterion evaluates controls related to system resilience, redundancy, failover mechanisms, and disaster recovery planning.
  3. Processing Integrity (Optional): Processing integrity ensures the accuracy, completeness, and validity of data processing, as well as the integrity of system outputs. This criterion focuses on controls related to data validation, error handling, processing accuracy, and reconciliation processes.
  4. Confidentiality (Optional): Confidentiality addresses the protection of sensitive information from unauthorized access or disclosure. It includes controls related to data classification, access controls, encryption, data masking, and confidentiality agreements.
  5. Privacy (Optional): Privacy assesses whether personal information is collected, used, disclosed, and disposed of in accordance with applicable privacy laws, regulations, and contractual obligations. This criterion evaluates controls related to data privacy policies, consent mechanisms, data retention practices, and individual rights management.

Each Trust Service Criterion is evaluated against predefined criteria and control objectives, with the goal of providing assurance to stakeholders regarding the effectiveness of a service organization’s controls related to security, availability, processing integrity, confidentiality, and privacy. Only the SOC 2 Security TSC is required. The remaining four are optional and depend on the type of commitments made to your customers in contracts or policies.

By undergoing SOC 2 audits and achieving compliance with the Trust Service Criteria, service organizations can demonstrate their commitment to protecting customer data and meeting the highest standards of trust and security.

For example,

  1. If your organization makes any commitment regarding service availability (i.e., uptime of 90%), then the availability of TSC is a good one to add
  2. If your organization makes any commitments regarding the level of data encryption in place and keeping your customer’s data confidential, then the confidentiality TSC is a good one to add
  3. If your organization makes any commitments regarding data or financial processing, processing integrity needs to be added to your scope
  4. If your organization creates, collects, transmits, uses, or stores personal information, you should consider adding criteria from the Privacy criteria

The decision to add the optional TSC is up to each organization and really depends on any commitments made to customers in contracts or policies.

Type 1 or Type 2?

As part of your audit, you need to let the auditor know whether a Type 1 or Type 2 audit will be conducted.

The rule of thumb is that if this is your first SOC 2, start with a Type 1 audit, then do a Type 2 audit.

Type 1 is good for first-timers. A Type 1 is only assessing the ‘design’ of a control and generally requires only sample documentation of one (1) for each control. A Type 1 is faster to complete than a Type 2.

Type 2 is assessing the effectiveness of the controls over a period of time. Auditors expect to provide a random sample of documentation per control during a specific period.

Observation period

A SOC 2 observation period is the specific duration during which the auditor is assessing your controls against the SOC 2 criteria.

This effectively means that the evidence that is provided to your auditor needs to be within the months and years specified in your observation period.

For a SOC 2, the most common observation periods are:

  1. 3 months
  2. 6 months
  3. 12 months

Scoping guidance template

Scoping guidance
Provide a detailed description of your organization’s products or services.

Focus on the product or service under review.

Provide the type of data and people that flow through the product or service under review.
Please provide a list of systems or tools that flow through or support the product or service under review.
Please provide the list of critical vendors being used to support the product or service under review.
Confirm your SOC 2 audit Trust Service Criteria (TSC) scope. 

□      (Mandatory) Security

□      ‍(Optional) Availability

□      (Optional) Confidentiality

□      (Optional) Processing integrity

□      (Optional) Privacy

Confirm your SOC 2 objective:

□      Type 1 – At a point of time. Test of design only

□      Type 2 – During a review period. Test of design and operating effectiveness

Confirm your observation period

□      3 months (MONTH/YEAR – MONTH/YEAR)

□      6 months (MONTH/YEAR – MONTH/YEAR)

□      12 months (MONTH/YEAR – MONTH/YEAR)

 

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