By Ramyar Daneshgar
Security Engineer & Analyst at CybersecurityAttorney.com

Disclaimer: This article is for educational purposes only and does not constitute legal advice.

What is SOC 2?

SOC 2 stands for System and Organization Controls 2, a compliance framework developed by the American Institute of Certified Public Accountants (AICPA). It defines how service organizations—especially technology and SaaS companies—should manage, process, and protect customer data based on five Trust Services Criteria (TSC):

1. Security
2. Availability
3. Processing Integrity
4. Confidentiality
5. Privacy

SOC 2 is not a legal requirement, but it has become a industry standard for data security assurance, especially in B2B SaaS. It is often mandated contractually by enterprise customers and used to prove due diligence under privacy laws like GDPR, CPRA, and the FTC Safeguards Rule.

SOC 2 Type I vs. Type II

• SOC 2 Type I: Validates that your controls are designed correctly as of a specific date.
• SOC 2 Type II: Tests the operational effectiveness of those controls over a defined period (typically 3–12 months).

Most customers demand SOC 2 Type II.

Trust Services Criteria (TSC) Breakdown

1. Security
   You must protect systems, data, and infrastructure from unauthorized access, misuse, or breach. This is the foundation of SOC 2 and required for every company being audited.

2. Availability
   You must ensure your service is up and running as promised. This applies if you make uptime guarantees (SLAs), or your customers rely on your system for critical operations.

3. Processing Integrity
   Your system must process data completely, accurately, and as intended. Customers must trust that your platform does not lose or corrupt data during processing.

4. Confidentiality
   You must protect sensitive or proprietary information from being disclosed to unauthorized parties.

5. Privacy
   You must handle personal information in accordance with your privacy policy and applicable laws like GDPR, CPRA, and CCPA.

Key Requirements:

SOC 2 vs. Privacy Law Obligations

SOC 2 Audit Process: What You’ll Need to Do

Once your controls are in place, a licensed CPA firm will conduct a SOC 2 Type II audit to evaluate their effectiveness over time. The process involves four clear phases:

Step 1: Readiness Assessment

Before the audit window begins, your team will assess which Trust Services Criteria (TSCs) are in scope and perform a gap analysis.

Internal preparation includes:

• Selecting applicable TSCs
• Mapping your controls to the AICPA Common Criteria (CC1.1–CC9.2)
• Drafting your system description
• Assigning owners for each control

Step 2: Remediation and Documentation

You’ll implement missing controls and document your practices clearly.

Required documentation includes:

• Information Security Policy
• Access Control Policy
• Incident Response Plan
• Change Management Policy
• Vendor Risk Management Policy
• Data Retention and Disposal Policy (if applicable)
• Business Continuity / Disaster Recovery Plan (if Availability is in scope)
• Security Awareness & Training Policy

Step 3: Monitoring Period (3–12 months)

This is the core of a Type II audit. You’ll need to operate your controls and keep detailed records that demonstrate ongoing compliance.

Key records to maintain:

• MFA configuration and access logs
• Quarterly access review reports
• Change tickets with approvals (
• JIRA)
• GitHub/GitLab pull request logs
• Backup logs and restore test confirmations
• Incident postmortem documentation
• Employee security training records
• Vendor assessments and signed DPAs

Step 4: Independent Audit

A licensed SOC 2 auditor will evaluate your system description, control evidence, and how well your organization operated its controls over the defined period.

The final SOC 2 report includes:

• Section 1: Management's Assertion
• Section 2: Independent Auditor’s Opinion
• Section 3: System Description
• Section 4: Control Matrix with test results and findings

What Happens After You Pass SOC 2

1. You Receive Your Official SOC 2 Type II Report

The report includes:

• Section 1: Management’s Assertion – Your formal statement that your controls are accurate and in place.
• Section 2: Auditor’s Opinion – Whether the auditor believes your controls were designed and operated effectively.
• Section 3: System Description – A detailed narrative about your infrastructure, services, boundaries, and control environment.
• Section 4: Control Matrix – Each control tested, mapped to AICPA Common Criteria, and whether it passed or had exceptions.

This document is confidential and is typically shared under NDA.

2. You Can Now Share It with Customers and Prospects

Host your SOC 2 report in a secure portal, such as the Drata Trust Center or a restricted-access Google Drive. Only share the report under a mutual non-disclosure agreement (NDA). When responding to vendor security reviews or due diligence requests, reference the report directly— “We are SOC 2 Type II compliant. Please see the attached audit report for full control coverage and auditor validation.” This approach streamlines procurement and often eliminates the need to complete lengthy security questionnaires.

3. You Can Publicly Promote SOC 2 Compliance (Carefully)

Once certified, you are permitted to state:

• “SOC 2 Type II Compliant”
• “We’ve successfully completed a SOC 2 Type II audit conducted by [Audit Firm], covering the period from [Start Date] to [End Date].”

However, you may not:

• Publicly share the full SOC 2 report (it must be shared under NDA)
• Use the AICPA logo, seal, or any misleading language suggesting an official certification mark

4. Use the Report in RFPs and Enterprise Sales

• Reference it in vendor onboarding, procurement processes, and legal due diligence for partnerships or M&A.
• Reduce friction in selling to healthcare, fintech, HR, and public sector buyers.

5. Start Preparing for Your Next Audit

• SOC 2 Type II audits are annual, so the process repeats every 12 months.
• Begin:
  • Updating your system description
  • Maintaining your logs and evidence
  • Reviewing and tightening any controls that had exceptions

6. Map Your SOC 2 Controls to Other Frameworks

If you plan to pursue additional certifications ( ISO 27001, HIPAA, or FedRAMP), you can reuse most SOC 2 controls:

• Access control, logging, change management, DR, and vendor risk processes are all reusable artifacts.
• Build a control mapping matrix to avoid redundant work.

7. Leverage the Report to Reduce Legal and Regulatory Risk

Your report can demonstrate:

• Reasonable security under laws like CPRA, GDPR, and the FTC Act
• Compliance posture during a data breach or class action defense
• Due diligence in third-party vendor agreements

Summary: Use Your SOC 2 Report as an Asset

Final Thoughts

SOC 2 Type II compliance is not about perfection — it's about having the right controls in place, following your policies consistently, and being able to prove it. With the right preparation and documentation, your organization can use SOC 2 to build customer trust and reduce legal exposure.

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