# SOC 2 Control Matrix Reference ## Table of Contents 1. [Security — Common Criteria (CC1–CC9)](#security--common-criteria) 2. [Availability (A1)](#availability-a1) 3. [Confidentiality (C1)](#confidentiality-c1) 4. [Processing Integrity (PI1)](#processing-integrity-pi1) 5. [Privacy (P1–P8)](#privacy-p1p8) 6. [Control Statement Template](#control-statement-template) --- ## Security — Common Criteria ### CC1 — Control Environment | Criterion | What auditors look for | Common gap | |---|---|---| | CC1.1 | COSO principles demonstrated; commitment to integrity and ethical values | No code of conduct or ethics policy; leadership not visibly engaged | | CC1.2 | Board or equivalent oversight of security program | No documented board/executive security oversight; no meeting minutes | | CC1.3 | Org structure, reporting lines, authorities defined | Org chart not current; security roles undefined | | CC1.4 | Competent personnel; HR lifecycle controls | No background checks; no security training program | | CC1.5 | Accountability for security responsibilities | Performance goals don't include security; no enforcement | **Example control (CC1.4):** ``` Control ID: CC1.4-001 Title: Security Awareness Training Type: Preventive Owner: HR / Security Frequency: Annual (+ onboarding) Description: All employees complete annual security awareness training covering phishing, data handling, and incident reporting. Completion is tracked and non-completions escalated to managers. Evidence: Training completion report from LMS, onboarding checklist sign-offs Test: Inspect training platform report; confirm >95% completion within period; sample 5 employees to verify completion dates within 12 months. ``` --- ### CC2 — Communication and Information | Criterion | What auditors look for | Common gap | |---|---|---| | CC2.1 | Quality information available to support control objectives | Policies inaccessible or not distributed; no intranet/wiki | | CC2.2 | Internal communication about security responsibilities | Security updates not communicated; no all-hands or newsletter | | CC2.3 | External communication with customers, regulators, vendors | No process to notify customers of security incidents; SLA terms vague | --- ### CC3 — Risk Assessment | Criterion | What auditors look for | Common gap | |---|---|---| | CC3.1 | Defined risk objectives; risk tolerance stated | No written risk appetite or tolerance statement | | CC3.2 | Risk identification and analysis process | No formal risk assessment; informal or ad hoc only | | CC3.3 | Fraud risk considered | No fraud risk assessment or controls | | CC3.4 | Technology change risks assessed | Changes don't trigger risk reassessment | **Example control (CC3.2):** ``` Control ID: CC3.2-001 Title: Annual Risk Assessment Type: Detective Owner: CISO / Security Manager Frequency: Annual + event-driven Description: A formal risk assessment is performed annually, identifying threats, vulnerabilities, and likelihood/impact ratings. A risk register is maintained and reviewed quarterly by the security committee. Evidence: Risk register (dated), risk assessment report with sign-off, security committee meeting minutes Test: Inspect risk register; confirm dated within 12 months; verify management sign-off; confirm high risks have remediation owners. ``` --- ### CC4 — Monitoring Controls | Criterion | What auditors look for | Common gap | |---|---|---| | CC4.1 | Ongoing and separate evaluations of controls | No internal audits; no continuous monitoring program | | CC4.2 | Deficiencies evaluated and communicated | No deficiency tracking; findings not escalated | --- ### CC5 — Control Activities | Criterion | What auditors look for | Common gap | |---|---|---| | CC5.1 | Controls selected to mitigate risks | Controls not mapped to risks; no controls matrix | | CC5.2 | Technology controls deployed | No MFA, no endpoint protection, no SIEM | | CC5.3 | Policies and procedures deployed | Policies exist but not enforced; no procedures for key processes | --- ### CC6 — Logical and Physical Access Controls This is typically the most heavily tested area. | Criterion | What auditors look for | Common gap | |---|---|---| | CC6.1 | Logical access security measures | No MFA on critical systems; no SSO; shared accounts | | CC6.2 | New access provisioning authorized | No formal access request/approval process | | CC6.3 | Termination / role change access removal | Terminated employees not promptly de-provisioned (>24hr is a flag) | | CC6.4 | Access credentials protected | Passwords stored in plaintext; no PAM for privileged accounts | | CC6.5 | Logical access reviewed | No periodic user access reviews (quarterly/annual) | | CC6.6 | Logical access restricted from threats | No IDS/IPS; no network segmentation | | CC6.7 | Data transmission protected | Unencrypted data in transit; no TLS enforcement | | CC6.8 | Unauthorized software prevented | No application whitelisting or MDM; shadow IT uncontrolled | **Example control (CC6.3):** ``` Control ID: CC6.3-001 Title: Access Termination — Employee Offboarding Type: Preventive Owner: IT / HR Frequency: Event-driven (each termination) Description: Upon employee termination, IT disables all system access within 24 hours of the HR-initiated offboarding ticket. A checklist confirms: AD account disabled, SaaS app access revoked, VPN certificate revoked, hardware returned. HR confirms completion in the HRIS. Evidence: Offboarding tickets, access revocation logs, HRIS termination records Test: Select sample of 10–25 terminations in audit period; verify access was revoked within 24 hours using AD logs and ticket timestamps. ``` --- ### CC7 — System Operations | Criterion | What auditors look for | Common gap | |---|---|---| | CC7.1 | Vulnerability and malware detection | No vulnerability scanning; no EDR on endpoints | | CC7.2 | Monitoring for security events | No SIEM or log aggregation; alerts not reviewed | | CC7.3 | Security incidents evaluated and responded to | No incident response plan; incidents not documented | | CC7.4 | Security incidents contained and resolved | No IR runbook; no post-incident review process | | CC7.5 | Identified vulnerabilities remediated | No SLA for patching critical vulns; no patch cadence | --- ### CC8 — Change Management | Criterion | What auditors look for | Common gap | |---|---|---| | CC8.1 | Authorized, tested, and approved changes | Changes deployed without tickets or approval; no testing in staging | **Example control (CC8.1):** ``` Control ID: CC8.1-001 Title: Production Change Approval Type: Preventive Owner: Engineering / DevOps Frequency: Event-driven Description: All production changes require a change request ticket approved by an authorized reviewer (tech lead or manager) before deployment. Emergency changes require retroactive approval within 24 hours. Changes are tested in staging/QA before production promotion. Evidence: Change tickets with approvals, deployment logs, PR approvals in version control (GitHub/GitLab), JIRA/Linear ticket history Test: Sample 20–30 changes in audit period; verify each has prior approval, tester other than developer, and ticket closure with deployment confirmation. ``` --- ### CC9 — Risk Mitigation | Criterion | What auditors look for | Common gap | |---|---|---| | CC9.1 | Business disruption risk mitigation | No BCP; BCP untested | | CC9.2 | Vendor and business partner risk managed | No vendor inventory; no vendor assessments performed | --- ## Availability (A1) | Criterion | What auditors look for | Common gap | |---|---|---| | A1.1 | Capacity monitored and managed | No capacity monitoring; no alerting on resource thresholds | | A1.2 | Environmental threats managed; backups tested | No backup verification; no restore testing | | A1.3 | Recovery tested; RTO/RPO defined | RTO/RPO not defined; no DR test records | --- ## Confidentiality (C1) | Criterion | What auditors look for | Common gap | |---|---|---| | C1.1 | Confidential information identified and protected | No data classification; no data inventory | | C1.2 | Confidential information disposed of appropriately | No data retention/disposal policy; no certificate of destruction | --- ## Processing Integrity (PI1) | Criterion | What auditors look for | Common gap | |---|---|---| | PI1.1 | Processing complete, valid, accurate, timely, authorized | No input/output validation; no reconciliation controls | | PI1.2 | System inputs authorized | No authorization checks; no separation of duties | | PI1.3 | System outputs complete and accurate | No output verification or reconciliation | | PI1.4 | Processing errors detected and corrected | No error handling or alerting; errors silently discarded | | PI1.5 | Stored items protected | No integrity monitoring; no checksums | --- ## Privacy (P1–P8) | Criterion | What auditors look for | Common gap | |---|---|---| | P1 | Privacy notice provided to individuals | No privacy notice; notice doesn't match actual practices | | P2 | Choice and consent obtained | No consent mechanism; opt-out not honored | | P3 | Personal information collected only as stated | Collecting more data than disclosed; no data minimization | | P4 | Personal information used only as stated | Using PII for undisclosed purposes | | P5 | Personal information retained and disposed per policy | No retention schedule; PII kept indefinitely | | P6 | Personal information disclosed only as authorized | No data sharing agreements; unauthorized third-party access | | P7 | Personal information quality maintained | No process to update/correct inaccurate data | | P8 | Privacy complaints and inquiries handled | No DSR (Data Subject Request) process; no privacy contact | --- ## Control Statement Template ``` Control ID: [TSC-criterion-sequence, e.g., CC6.1-002] TSC Criterion: [e.g., CC6.1 – Logical Access Security Measures] Control Title: [Short descriptive name] Control Type: [Preventive | Detective | Corrective] Control Owner: [Role/team] Frequency: [Continuous | Daily | Weekly | Monthly | Quarterly | Annual | Event-driven] Description: [What the control does, who performs it, how it works, and what systems/processes are covered. 2–5 sentences.] Evidence: [Artifacts produced by this control that prove it operates: logs, reports, tickets, sign-offs, screenshots, exports.] Test Procedure:[How an auditor would test this: sample size, data sources, pass/fail criteria. Match Type 1 (design) vs Type 2 (operating).] Related Policies: [Which policy governs this control] Linked Risks: [Which risks from risk register this control mitigates] ```