Achieving and maintaining SOC 2 Type 2 compliance is no small undertaking. It takes hundreds of hours of assessments, planning, and remediation just to lay the groundwork for the system of controls, which brings the organization into compliance. Though the process is daunting, starting early and consistently putting in a concerted effort make the process a whole lot easier.
This blog post shares the top IT challenges for organizations looking to become SOC 2 compliant as well as maintaining compliance. Everything shared here comes directly from our first-hand experience of achieving SOC 2 Type 2 compliance as well as helping our clients with their SOC 2 compliance needs and remediation.
1. Access Control
Access control plays a critical role in SOC 2 compliance since it helps the organization enforce security and privacy requirements related to the confidentiality and integrity of customer data. It allows you to manage and regulate who can access specific systems, applications, and data, as well as what actions they can perform once granted access.
Access control is, therefore, fundamental to security and privacy management in SOC 2. Without access control, it would be impossible to meet the trust services criteria, especially those related to security and confidentiality.
Robust access control requires implementing strong authentication and authorization mechanisms. But that’s not all, access control also involves enforcing the Principle of Least Privilege (POLP), monitoring user activities and logging access attempts and actions, physical access control, and extending access control practices to third-party vendors and service providers.
Properly implementing all of these access control mechanisms without hampering employee mobility, remote access, and productivity can be a real challenge.
2. Change Management
Change management is another crucial element necessary for achieving and maintaining SOC 2 compliance. In a complex business environment, changes to systems, software, configurations, and processes can introduce vulnerabilities, disrupt services, or compromise data security. And change management helps ensure that any changes implemented do not negatively impact the security, availability, and integrity of their systems and data.
Change management prevents the implementation of unauthorized or untested changes that could disrupt services or compromise data security. Thus, it plays an important role in helping organizations maintain the security, availability, and integrity of their systems and data in the face of frequent changes to their IT infrastructure and applications.
Another benefit of change management is that it helps maintain system availability, which is one of the trust services criteria in SOC 2. Planning and scheduling changes, which is an important part of the change management process, helps immensely in minimizing downtime and maintaining system availability.
Additionally, change management processes include documentation, tracking, and auditing of all changes. This provides a clear audit trail, which is necessary for demonstrating compliance during SOC 2 audits.
Despite all of the benefits of change management, organizations often struggle with it for several reasons. First, managing changes in large and complex IT environments can be challenging because of the heterogeneous mix of systems, applications, and technologies that require close coordination and thorough evaluation.
Second, there is often a general lack of awareness of the importance of change management leading to negligence and inadequate documentation. Consequently, most organizations struggle to maintain detailed records of all changes, which can make compliance and auditing difficult.
Third, lack of communication between teams and inadequate training in change management principles and procedures also impede change management efforts through lack of coordination and inconsistency in the application of procedures.
3. Incident Response
No matter how sophisticated security systems an organization has, it can never be completely immune to cyberattacks. A typical business faces tens if not hundreds of security threats daily. Sooner or later, the sheer volume of security incidents makes it quite probable that your organization will suffer a security breach.
Developing a plan to address such an eventuality is what incident response is all about. SOC 2 requires organizations to have effective incident response procedures in place to protect sensitive customer data and demonstrate due diligence in safeguarding it.
Implementing incident response plans involves creating a systematic and organized approach to addressing and managing security incidents when they occur, making sure relevant staff and departments are aware of their responsibilities and duties within these plans, and testing to ensure that these plans work as intended. The ultimate goal is to minimize the damage caused by a security incident, reduce recovery time and costs, and protect sensitive data.
The most significant challenge to incident response is a lack of preparedness, which leads to confusion and delayed responses when incidents occur. This lack of preparedness may stem from several reasons, including resource constraints, lack of expertise, and falling into a false sense of security.
The other major challenge is technical and includes reasons such as the complexity of the IT environment, lack of advanced threat detection tools, alert overload due to false positives, failure to keep up with the changing threat landscape, and inability to maintain detailed records and documentation of incidents and responses, which is essential for SOC 2 compliance.
4. Vendor Management
Most service organizations rely on third-party vendors, suppliers, or service providers in some form or the other. The security practices of these vendors can directly impact the security of an organization’s customer data. So, vendor management plays a significant role in SOC 2 compliance since it pertains to the security and integrity of customer data and the services provided by service organizations.
Vendor management typically involves conducting a thorough risk assessment and due diligence to evaluate the vendor's security posture, formal contracts or service level agreements (SLAs), that specify the security expectations and requirements, and monitoring and oversight of third-party vendors to ensure they maintain the agreed-upon security standards.
Your SOC 2 compliance journey will be a lot smoother if you partner with vendors that are themselves SOC 2 compliant. This ensures that their regulatory oversight, internal governance, and risk management policies and practices meet the required standards.
However, if your vendors aren’t SOC 2 compliant, vendor management can be problematic. The key challenges include;
Requirement of regular security assessments, audits, and performance evaluations.
Coordinating incident response efforts with the vendor in the event of a security incident or data breach involving them.
Monitoring changes made by vendors that can impact the services provided or the security of customer data.
Assessing and monitoring the vendor’s sub-service organizations.
5. Training and Awareness
Training and awareness involve ensuring that your employees are knowledgeable about security policies, procedures, and best practices. This contributes to several key aspects of SOC 2 compliance including
Maintaining security controls that align with SOC 2 criteria by helping employees understand and adhere to established security policies and procedures.
Raising awareness of security threats and risks, which is vital for effective reporting and incident response.
Better equipping employees to implement and maintain security controls effectively.
Ensuring that the incident response team is well prepared to act swiftly and effectively.
Helping employees understand the importance of maintaining detailed records of security activities and their roles and responsibilities in achieving compliance.
Despite the importance of training and awareness, it is often severely neglected by most organizations. This neglect is often attributed to resource constraints, lack of stakeholder engagement, remote or hybrid work environments, or the inability to measure effectiveness.
Training and awareness are critical elements of a comprehensive security program that supports SOC 2 compliance. Effective training and awareness programs help foster a security-conscious organizational culture where all employees understand the importance of security and become active participants in maintaining security and data, actively contributing to SOC 2 compliance.
Here are a few resources to help you create a security-conscious culture at your workplace:
6. Documentation and Record-Keeping
SOC 2 requires organizations to not just meet requirements but also demonstrate compliance with those requirements. The compliance is verified through third-party audits in which documentation and record-keeping play an integral part.
However, documentation and record-keeping are not restricted to the demonstration of compliance. They are essential for several aspects of the compliance process, including
Displaying evidence that adequate security controls exist, are well-defined, and are being followed.
Creating audit trails that allow auditors to trace the activities and events related to the security and processing of customer data.
Recording and reporting security incidents, including the details of the incident, response activities, and the steps taken to mitigate the impact.
Serving as evidence to support the organization's position in the event of disputes or legal actions.
Displaying evidence that policies and procedures are well-defined and communicated to employees.
Documentation and record-keeping can be challenging due to various factors. Without the right tools and technologies, record-keeping is extremely time-consuming and resource-intensive. In complex IT environments, maintaining records for a multitude of systems, processes, and controls can be overwhelming, considering that organizations must document a wide range of activities, from security policies to incident responses.
In addition, there are aspects of documentation and record-keeping that add to the complexity, including version control, proper storage and retrieval, varying retention requirements based on legal, regulatory, or organizational policies, and ensuring consistency.
Conclusion
The challenges shared above are typically complex and interconnected. Effectively addressing them requires a holistic approach to security and compliance. Most SOC 2 compliant organizations engage with security experts and auditors to help navigate these challenges and ensure that they meet SOC 2 requirements effectively.
Are you looking to achieve and maintain SOC 2 compliance? If you are in need of IT and security assistance from a SOC 2 compliant MSP, you can reach out to us by clicking the button below.
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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.