Whether an organization is operating onsite, remotely, or in a hybrid environment, the process of becoming SOC 2 compliant is largely similar. However, it can vary slightly based on the specific controls and processes required. Operating in a fully remote environment can have a larger impact on your SOC 2 compliance as you may require greater or lesser emphasis on specific controls and processes.
In this blog post, we take a look at how being fully remote can impact your SOC 2 compliance process and what you can do to make the process easier.
The Upside To Being Fully Remote
Let me share the good news first. There are a couple of benefits of being fully remote that make getting or maintaining SOC 2 compliance a little easier.
First, since you don’t have a centralized office space, there is no requirement for physical security. You don’t need to worry about policies and security measures to safeguard against physical security threats such as tailgating and piggybacking. This simplifies certain aspects of security control implementation.
Second, fully remote companies, typically, have a strong culture of documentation and policies. In a remote environment, where most of the work and communication happens asynchronously, robust documentation provides the necessary guidance enabling employees to operate autonomously. A typical fully remote business has policies for secure remote access, data handling procedures, incident response plans, etc. So having well-documented policies and procedures puts fully remote organizations naturally in a good position to achieve SOC 2 compliance.
SOC 2 Compliance Challenges For Fully Remote Organizations
You may already know the variety of IT and security challenges that a fully remote environment brings. Let’s look at these challenges from the perspective of the five distinct “trust services criteria”.
1. Security
A remote work environment has many vulnerabilities that need to be plugged in, consequently is one of the biggest concerns for SOC 2 compliance. Home networks, especially those with IoT devices, present many risks because they lack the enterprise-grade security measures typically present in office networks.
It’s also common practice among remote workers to use their personal devices for work-related tasks. Whether it's using personal smartphones for two-factor authentication (2FA), accessing work emails on the go, or communicating with the team through platforms like Slack or Microsoft Teams, the distinction between personal and professional realms has become more nuanced. While this enhances flexibility and productivity, it also heightens security risks for the organization.
Additionally, remote workers are also a softer target for cybercriminals since they are outside the more secure corporate network. So it is not surprising that since 2020, there has been an exponential increase in the number of cyberattacks on remote employees. What’s more concerning is that such attacks have grown not just in number but also in sophistication.
These security concerns necessitate robust security controls, policies, and practices to adequately satisfy the requirements of SOC 2.
2. Availability
The availability criterion in SOC 2 refers to the idea that the organization’s systems should be available for operation and use as committed or agreed. It encompasses the availability and accessibility of systems, products, and services.
Fully remote businesses face many challenges in ensuring the availability of systems and data, the chief among them is internet connectivity. Remote work heavily relies on internet connectivity and availability is affected if remote employees face Internet or power outages. While office networks have a fallback power supply and secondary internet service provider (ISP) to mitigate outages, home networks typically don’t have such fail-safe measures.
A remote work environment also relies on various cloud services and infrastructure. The reliability of these services is crucial for maintaining availability. Disruptions in cloud services or data centers could impact system availability. To ensure that such disruption doesn’t compromise availability, robust redundancy and backup measures will be required.
3. Processing Integrity
The processing integrity criterion in SOC 2 focuses on the protection of systems and data against unauthorized changes. SOC 2-compliant organizations need to ensure that data processing is complete, valid, accurate, timely, and authorized. Being fully remote can have several implications for processing integrity.
Remote work overwhelmingly depends on seamless access to corporate resources. Ensuring that only authorized individuals can initiate or approve transactions is critical for processing integrity. So, while facilitating easy access to systems and data, organizations need to ensure that only authorized individuals can initiate or approve changes. Additionally, communication channels also need to be secured to prevent data tampering during transmission.
One often overlooked aspect necessary for ensuring processing integrity is change management. Changes to systems or processes, especially those initiated by remote employees, should undergo thorough testing and validation to ensure that they do not compromise processing integrity.
4. Confidentiality
The confidentiality criterion in SOC 2 is concerned with protecting sensitive information from unauthorized access and disclosure. Fully remote organizations must have a greater focus on confidentiality because they need to ensure that sensitive data is protected while it is being accessed by different users from varied geographical locations.
Sensitive information must be handled securely no matter where it is accessed from. Secure remote access mechanisms such as virtual private networks (VPNs) and two-factor authentication (2FA) must be implemented to protect against unauthorized access. Robust access controls such as the principle of least privilege (PoLP) and zero trust architecture are also critical for ensuring that employees have access only to the information necessary for their roles and preventing unauthorized access.
The use of encryption for data both in transit and at rest must also be emphasized. This ensures that even if data is intercepted during transmission or if a device is lost or stolen, the information remains confidential and secure. Collaboration tools used by the organization must also be selected based on their security, encryption, and access control features. This ensures that confidential discussions and file sharing within remote teams are adequately protected.
And of course, it goes without saying that strong endpoint security measures, including antivirus software, device encryption, and mobile device management (MDM) solutions are a must to mitigate the risk of unauthorized access through compromised devices.
5. Privacy
The privacy criterion in SOC 2 is concerned with how your system collects, retains, discloses, and disposes of personal information. All such systems and data need to conform to your organization’s privacy policy and with AICPA’s generally accepted privacy principles (GAPP).
To adequately secure personal information, whether it belongs to employees or clients, organizations must implement robust security measures, such as encryption and access controls, to protect against unauthorized access or data breaches. If the other trust services criteria are already addressed, then the security measures required for privacy should already be in place.
That leaves two distinct areas specific to the privacy criterion. First, concerns data retention and disposal. Remote organizations must clearly define and communicate data retention and disposal policies for personal information. They also need to establish secure processes that ensure remote employees adhere to these policies.
Second, remote organizations also need to assess and manage the privacy practices of third-party vendors, especially those involved in remote work support services. It needs to be ensured that these vendors comply with the organization's privacy requirements and standards.
SOC 2 Compliance Best Practices For Fully Remote Organizations
Although achieving SOC 2 compliance is a daunting task, if your organization starts preparing for compliance early, the process will go a lot more smoothly. No matter if your organization is fully remote, hybrid, or on-site, here are some best practices that will help your organization achieve SOC 2 compliance.
Plan Thoroughly Before You Start
SOC 2 compliance is a long process, spanning several months, and involves many people across multiple functions. Planning ahead will allow you to evaluate if you have the necessary resources and expected timeline for achieving compliance. Another important function of planning is that it helps you confirm whether SOC 2 is the right compliance for your organization. Getting compliance is a time-consuming and expensive process and you don’t want to find halfway through that you actually need some other compliance.
Perform A Risk Assessment
Performing a risk assessment is one of the key steps in your SOC 2 preparation. A comprehensive risk assessment helps you identify and analyze potential risks, and identify the security measures that are best suited to mitigate those risks.
Risk assessment enables you to make informed decisions about remote working risks and ensure that your security controls adequately mitigate those risks. Therefore, it is crucial to assess all areas, including the security of home networks, the use of personal devices, and any other factors that may impact SOC 2 compliance.
I have covered cybersecurity risk assessment in detail in an earlier blog post that you can access here: How To Perform A Cybersecurity Risk Assessment.
Update Policies and Procedures
If you are transitioning to a fully remote setup, review and update all your policies and procedures to reflect the remote work environment. If your organization doesn’t have them already, pay special attention to tailor remote access policies, data handling procedures, and incident response plans to address the specific challenges of remote work.
Monitor Continuously
Implement monitoring mechanisms that ensure security controls are consistently applied in the remote work setting. Monitoring should include reviews of access logs, security audits, and vigilance against emerging threats.
Invest In Employee Training and Awareness
While it does offer many advantages, remote work is not without its challenges. So it is not uncommon for remote workers to be mentally exhausted or distracted, making them prone to mistakes and errors, and an easy target for cyberattacks.
Therefore, remote employees are in greater need of training on security practices, compliance requirements, and the organization's policies. Regular communication and awareness programs can help reinforce the importance of maintaining SOC 2 compliance and creating a security-conscious culture in general.
Partner With A Good Vendor Early
SOC 2 compliance requires you to not just show that you have adequate policies in place but also demonstrate that you are conforming with your policies. To satisfy this, you will require a system to collect evidence relating to your SOC 2 controls.
Gathering and retaining evidence of your security controls is a meticulous process, and performing this manually is thoroughly exhausting, to say the least. So you need to partner with a vendor who will help automate the process of collecting and storing evidence of your security controls. They can also help you through the compliance process and avoid common pitfalls.
Keep People In The Loop
As mentioned earlier, SOC 2 compliance is a long process that requires effort from your whole team. At some point, everyone will have to read policies, complete training, or contribute in some way. So it’s in the organization’s best interest to get everyone on the same page, helping them understand how compliance might affect them, its necessity, their responsibilities, and the level of effort required of them for achieving compliance.
Conclusion
Organizations pursue SOC 2 compliance for various reasons. Some want to demonstrate to customers and partners that they take the security and privacy of their data seriously. Others do it because they want a competitive edge in the marketplace. While others do it to establish and maintain effective data security and risk management practices.
No matter your reason for pursuing SOC 2, the overarching goal is to establish and maintain a secure and trustworthy environment for handling sensitive data. Achieving SOC 2 compliance is a massive undertaking requiring robust administrative, physical, and technical controls.
Starting your SOC 2 compliance preparations early with a comprehensive plan and the right technology partner make a huge difference in your compliance journey.
Getting your business ready for SOC 2 compliance is a massive process. We have helped many of our clients achieve and maintain their SOC 2 reports. If you are interested in talking to us about risk assessment and audit preparation for SOC 2, HIPAA, or any other compliance, reach out to us by clicking the button below.
If you liked the blog, please share it with your friends
About The Author
Hari SubediMarketing Manager at Jones IT
Hari is an online marketing professional with a focus on content marketing. He writes on topics related to IT, Security, and Small Business. He is also the founder and managing director of Girivar Kft., a business services company located in Budapest, Hungary.