How the Trust Services Criteria are organized
| Group | Covers |
|---|---|
| CC1 | Control environment: integrity, oversight, structure, competence, accountability |
| CC2 | Communication and information |
| CC3 | Risk assessment, including fraud risk and change |
| CC4 | Monitoring of controls |
| CC5 | Control activities and policies |
| CC6 | Logical and physical access |
| CC7 | System operations: detection, monitoring, incidents |
| CC8 | Change management |
| CC9 | Risk mitigation, including vendors and business disruption |
Availability, Confidentiality, Processing Integrity and Privacy each add their own criteria when you put them in scope.
Policies and governance (CC1, CC2, CC5)
- Information security policy, approved by leadership and reviewed yearly
- Acceptable use, access control, change management, incident response, vendor management, data classification and retention, business continuity policies
- An org chart and named owners for security
- Employees acknowledge the policies at hire and yearly
- A code of conduct, and a way to report concerns
Risk assessment (CC3, CC9)
- A risk register, reviewed at least yearly and after major changes
- Each risk with a likelihood, an impact, an owner and a treatment
- Vendor inventory, with security reviews for critical vendors and their SOC reports on file
- Business continuity and disaster recovery plans, tested
Access control (CC6)
- Single sign-on where the apps support it, and multi-factor authentication everywhere
- Access granted by role, approved, and recorded in a ticket
- Quarterly access reviews of production systems and key apps, with sign-off
- Access removed promptly at offboarding, with a checklist that proves it
- Encryption at rest and in transit, and managed devices with disk encryption and screen lock
- Physical access controls, or your data center provider’s SOC report
Operations and monitoring (CC4, CC7)
- Centralized logging for production and identity systems, with alerts someone acts on
- Vulnerability scanning on a schedule, with fix timelines by severity
- A recent penetration test, if your auditor or buyers expect one (see is a pen test mandatory)
- Endpoint protection on every company device
- An incident response plan, a tabletop exercise each year, and records of real incidents
Change management (CC8)
- Code changes reviewed by someone other than the author before production
- Branch protection that enforces the review
- Separate test and production environments
- Infrastructure changes tracked the same way, and emergency changes reviewed after the fact
People (CC1)
- Background checks at hire, where local law allows
- Security awareness training at hire and yearly, with completion records
- Signed confidentiality agreements
- Job descriptions for security roles, and performance reviews that include them
If you add other categories
- Availability: uptime commitments, capacity monitoring, backups restored on a schedule, and a disaster recovery test with results.
- Confidentiality: a list of the confidential data you hold, who may see it, how long you keep it and how it is destroyed.
- Processing Integrity: input checks, error handling and reconciliation for the processing customers rely on.
- Privacy: your privacy notice, consent, access and deletion requests, and how personal data is shared with vendors.
Each category adds criteria, controls and audit time. Add one only when a customer asks for it or your contracts promise it.
The evidence checklist
A control without evidence is a control the auditor cannot test. Before the period starts, check that each item above produces at least one of these, on a schedule:
- A ticket or approval record
- A system export or screenshot with a date
- A signed or acknowledged document
- A log or report generated by the tool itself
Then keep complete population lists of new hires, leavers, changes and incidents. Auditors sample from them, and an incomplete list is a finding on its own. Doing this from a spreadsheet is possible; SOC 2 without a GRC tool shows how. The order of the steps that follow is in the SOC 2 audit process.
With AccuSights: we turn the criteria into your control list, write the policies, connect the evidence to your systems so it collects itself, and watch each control so gaps are fixed before the auditor samples them.