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SOC 2 Type 2 Audit Review Period Items

To maintain readiness for your next SOC 2 Type 2 audit, please consider the following:  For any controls/tests that you set as weekly or m...

Written by Brady Price

To maintain readiness for your next SOC 2 Type 2 audit, please consider the following:

For any controls/tests that you set as weekly or monthly, evidence needs to be retained for every week or month within the Type 2 window.

Quarterly

For quarterly controls/tests, evidence needs to be refreshed for every quarter within the Type 2 window.

  • Secureframe test: User access reviews

    • Remember that this includes non-integrated in-scope tools and your developed application

  • Secureframe tests: External vulnerability scanning, Internal vulnerability scanning

    • Remember that “external” refers to your web application and any public-facing endpoints.

Annual

For annual and semi-annual controls/tests, you only need evidence at least once in the year prior to the end of the Type 2 window. In other words, these don’t need to be refreshed when going from a Type 1 to a Type 2 window shorter than a year (i.e. 3, 6, or 9 months).

  • Review workstations, assets, and cloud resources annually - see “Asset List” section below for continuous monitoring items

    • You can evidence this is to utilize tasks for "Cloud infrastructure asset inventory", "User endpoint inventory", and "Version control repository inventory" tests to indicate a review.

  • Secureframe test: Security incident tabletop exercises

  • Secureframe test: Business continuity and disaster recovery tabletop exercises

  • Secureframe test: Backup restoration testing

  • Secureframe test: Board of directors meeting minutes

    • Or senior leadership meeting minutes if no board of directors

  • Secureframe test: Annual performance review

    • For employees who have been with the organization for at least one year)

  • Secureframe test: Annual security awareness training

  • All policy acceptance-related tests as applicable under the ORG-16 control

  • Secureframe test: Risk assessment

    • Review and update the risk register, and add any new risks as appropriate

  • Secureframe tests: Vendor risk assessments, Vendor reviews

    • Procure and upload SOC 2 reports or equivalents annually as new reports come out. Review these reports and note any areas of concern on the respective vendor page.

  • Secureframe test: Penetration testing

  • Secureframe test: Baseline configurations

    • Review server baselines and configurations for networking ports, protocols, services, and firewalls.

Ad-hoc

The following control areas will be sampled by the auditor for occurrences during the Type 2 window:

  • New Hires

    • Access Onboarding Tickets

      • Tickets should track personnel name, start date, role, system permission grants, and final approval with a timestamp.

      • Secureframe test: User access tracking

    • Background Checks

      • Secureframe test: New hire screening

    • Security Training

      • Secureframe test: Security awareness training at hire

    • Policy Acceptance

      • Secureframe test: All policy acceptance-related tests as applicable under the ORG-16 control

  • Current Employees

    • Access Role Change and Transfer Tickets

      • Tickets should track personnel name, transfer date, system permission changes, and final approval with a timestamp.

      • Secureframe test: User access tracking

        • Remember that this includes non-integrated in-scope tools and your developed application

  • Terminated Employees

    • Access Offboarding Tickets

      • Tickets should track personnel name, end date, system permission revocations, and final approval with a timestamp.

      • Secureframe test: User access tracking

        • Remember that this includes non-integrated in-scope tools and your developed application

  • Code/Application Changes

    • All code changes must have pull requests that require branch protection/independent approval (dev can't push own code), CI testing, dependency testing, and SAST scanning prior to the code entering production. All code changes must be linked to a ticket with change context unless that context is provided sufficiently in the PR.

      • Secureframe tests: Code change tracking, Code pull request approvals, Version control branch approval configurations, Code dependency testing, Code integration testing, Code static analysis security testing

  • Infrastructure/System Changes

    • Major/critical infra changes made via infra as a code, management console, CLI, etc. must have a ticket providing context of the change along with formal change approval. Examples of major changes include: spinning up a new prod DB, exposing VPCs, configuring a firewall, etc.

      • Secureframe test: System change tracking and resolution

  • Security Incidents

    • All incidents must be assigned a priority and tracked to remediation via a ticketing system. Incident progression and updates should be documented in the ticket. Upon resolution, incidents must undergo a lessons learned process to reflect on incident findings and ways to prevent similar incidents in the future. Tracking should include any security concerns communicated internally or externally.

      • Secureframe tests: Incident tracking and resolution, Address critical security incidents, Security incident lessons learned

  • Asset List

    • All cloud assets, code repos, and user endpoints must have an owner assigned.

      • Secureframe tests: User endpoint ownership, Version control repository ownership, Cloud infrastructure asset ownership

    • User endpoints should be encrypted-at-rest, be compliant with company password policy, and have AV installed. It is also recommended to enforce security updates, screen lock policy, and firewall enforcement.

      • Secureframe tests: Hard drive encryption for user endpoints, Password policy enforcement/monitoring for user endpoints, Automatic security update enforcement for user endpoints, Screen lock enforcement for user endpoints, Anti-malware enforcement for user endpoints, Firewall enforcement/monitoring for user endpoints

  • Data Disposal List

    • Data disposal requests from customers, vendors, and other external parties must be addressed based on SLAs / regulatory obligations - these requests must be documented and tracked.

      • Secureframe test: Deletion and retention of customer data

  • Customers

    • Signed contracts / MSAs for customers (unless signed up via terms of service).

      • Secureframe tests: Customer confidentiality and security requirements, Confidentiality requirements in agreements

  • Vendors

    • Signed contracts / MSAs for vendors (unless signed up via their terms of service)

      • Secureframe test: Vendor confidentiality and security requirements

Configuration tests that required manual upload screenshots to pass (i.e. password screenshots) may need to be re-observed by the auditor with a time stamp dated within the Type 2 period. Be sure to set the test interval to annual so you can be prompted for an update during the next cycle.

Integration and Platform tests: just keep them green throughout the year!

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