SaaS 创始人如何实现 SOC 2 合规

SOC 2 Compliance Checklist 

Here is the TL:DR version of what SaaS founders need to know about the SOC 2 compliance process. 

• Understand the two types of SOC 2 Compliance. 

• Identify if you need Type 1 or Type 2 

• Figure out when it makes sense to start this process

• Scope out the costs 

• Select the right SOC 2 compliance software 

• Hire a certified auditing firm

• Assemble your internal compliance team 

• Prepare necessary documentation and evidence ahead of the audit 

• Conduct a gap analysis 

• Develop and implement security and compliance policies and processes

• Establish additional risk management strategies 

• Create or update incident response plans 

• Enhance employee training and awareness programs 

• Fix any identified gaps and security issues from the audit

• Develop systems and processes for maintaining SOC 2 compliance

• Complete annual SOC 2 audits 

Read on for the full guide to SOC 2 compliance. 👇

What is SOC 2 compliance? 

SOC 2 is a security framework defining how software companies should manage, process, and store customer data. It was developed by the American Institute of CPAs and is based on the Trust Services Criteria (TSC) in 2010.  

SOC 2 compliance by service organizations is voluntary. However, compliance with SOC 2 standards shows that the group maintains a high level of information security and handles sensitive information responsibly. 

Understanding the five Trust Service Criteria (TSC)

Outside auditors who issue SOC 2 certification assess how well vendors comply with one or more of the five Trust Service Criteria (TSC).

These principles are:

• Security — How well the system is protected against unauthorized access, such as the ability of the IT security tools to prevent security breaches, unauthorized access to data, prevent potential system abuse, and misuse of software.

• Availability — The accessibility of the system, services, or products as outlined by a service level agreement or contract. For example, the stated minimum acceptable performance level for system availability or agreement regarding monitoring of network performance, handling security incidents, or site failover.

• Processing Integrity — Assess whether a system achieves its purpose or not, like providing the right data at the right time and place. But it does not necessarily imply data integrity (such as if data errors existed before being put into the system, the processing entity isn’t responsible for detecting the errors).

• Confidentiality — Assess if data access and disclosure is restricted appropriately, such as sensitive data being accessible by only those who need access. Other examples include encryption of confidential information during transmission, network and application firewalls, and access controls. 

• Privacy — How well the system’s collection, retention, use, disclosure, and disposal of sensitive information conforms to the company’s privacy notice and the AICPA’s generally accepted privacy principles, including protecting this information from unauthorized access.

However, all five principles won’t necessarily apply to every organization.

Types of SOC 2 Compliance

There are two primary types of SOC 2 compliance — Type 1 and Type 2.

Type 1

This describes an organization’s use of compliant systems and processes at a specific point in time and if it will meet the relevant TSC principles. The report will state all controls in use and that they are properly enforced and designed.

TL:DR

• Less controls 

• Less requirements 

• (Slightly) easier to get 

Type 2

Type 2 looks at compliant systems and processes and their effectiveness over a time period, typically between 3 to 12 months. This report will also affirm that the organization’s controls are operationally effective.

TL:DR

• Expensive 

• Takes longer to get 

• More controls 

When should a SaaS company get SOC 2 compliant?

Legally, SOC 2 is not required. However, many SaaS companies begin looking into SOC 2 compliance when they’re moving upmarket and selling to enterprise companies — because most enterprise customers and prospects will require SOC 2 auditing, including having a SOC 2 report. 

However, there’s an argument that SaaS companies that aim to work with enterprise-level organizations should be proactive — starting the compliance process as soon as possible. This allows them to be ready with the information enterprise clients need. Plus, it can help ensure the SaaS company doesn’t become a cybersecurity victim during their early start-up phase. 

How long does it take to become SOC 2 compliant?

Most SaaS companies first need to prepare, which can take three to six months. Then the audit can last between six months and one year for a Type 2 audit.

Type 1 audits are much faster to complete, but these will still take 1-3 months.  

Becoming compliant has numerous benefits for SaaS companies, including:

• Giving you a competitive advantage in the market

• Showing clients your dedication to security and data privacy

• Building trust and confidence 

• Improved operational efficiency

• Reducing the risk of cyber attacks and data breaches

• Making cybersecurity a priority in your company’s culture

• Selling to more enterprise clients

• Getting through procurement  

Pro Tip: Many choose to go through the HIPAA compliance process at the same time, since the process has many overlaps. It will add time to the process, but it could be worth it if you are looking to sell into the healthcare sector.  

How much does it cost to become SOC 2 compliant?

The cost will vary depending on your company and any complexities that might be unique to your situation. On the low end, you can expect to pay at least $25,000 to become SOC 2 compliant. However, most will end up paying more. For instance, SignWell paid around $40,000 to become SOC 2 Compliant, with $12,000 in software costs, $15,000 to auditors, and $13,000 in internal development costs (to implement or fix controls). 

Understanding the SOC 2 Audit Compliance process 

Selecting SOC 2 Compliance auditing software 

A SOC 2 Audit Compliance is a process that takes time to gather documentation, ensure proper processes are in place, and more. To help, many companies turn to automated security and compliance platforms to help scale security practices, get compliant, and stay compliant.

Two popular options are Vanta and Drata.

While this software will cost at least $10,000, these security platforms can help streamline evidence collection and help if you need to comply with multiple compliance frameworks.

Platforms like Vanta and Drata help you connect your tools and infrastructure, automate much of the work required for security audits, make it easy to scale securely, and provide continuous monitoring to ensure you become compliant and stay that way. 

When investigating using platforms like VANTA and DRATA, be sure the programs integrate with the tools you use and let you choose the audit firm or CPA firm you want. 

Pro Tip: While you can technically get SOC 2 certified without using software, like Vanta or Drata, it is generally not worth it. It is going to take you a ton of time and manual work.  

Selecting a certified public accounting (CPA) firm

Selecting the right certified public accounting firm is a mandatory step in the SOC 2 compliance process. It is important to ensure you have a high-quality and smooth experience by an independent auditor who understands your industry. 

When evaluating auditing firms, look for:

• An auditor affiliated with the AICPA or a certified CPA firm

• Auditor or firm with experience in your industry and with vendors of a similar size

• Qualifications, including certifications and types of assessments they do

• An auditor with a style of communication that fits you and your company

• Someone who can explain the process, timeline, and how they will collect information

• Someone who has an in depth understanding of your tech stack 

Additionally, you’ll want to interview multiple auditors so you can select the right person for your situation and who understands the scope of your audit. Additionally, they should be able to address the time frame and what to expect. 

Assembling your internal SOC 2 Compliance team

You’ll want a comprehensive internal team overseeing your compliance initiative to ensure it stays on track and has an appropriate scope. You’ll want a team that can communicate and work well together so the preparation and auditing process doesn’t get slowed down.

Ideally, your internal team will include:

• An executive sponsor — who can clearly explain why your company is pursuing SOC 2

• A project manager — who can oversee and manage the responsibilities and ensure tasks are getting done on time

• Legal — your legal team can assist with creating and refining policies as well as work with third-party vendors and business partners regarding contracts

• IT  — your IT team will address security and technology needs to ensure you have the right technical functionality to pass the audit, such as detecting and responding to security incidents, maintaining data securely, and more  

Conducting the SOC 2 audit

The auditor may ask for some initial information. Many firms will administer a questionnaire to you and your team, gathering information on company procedures, IT infrastructure, controls, and policies. 

You’ll also want to address with them the scope of the audit, including the audit report type your organization needs. You can choose between a Type 1 audit or a Type 2 audit. 

• Type 1 audit — These types of audits are typically faster but don’t provide as much information. The audit evaluates whether your systems are set up according to the TSC.

• Type 2 audit — This audit type checks how your systems are designed and whether they work. These take longer because the independent auditor must run experiments to see if you pass. 

Additionally, you’ll need to determine which TSC you want to become compliant with. You don’t have to do all five TSC at the same time.

Preparing documentation and evidence

Once you’ve determined the scope of your audit, you’ll need to gather documentation and evidence about these systems and controls. The auditors require this to help understand how controls are supposed to work. 

Some types of documentation you may need include:

• Code of conduct and ethics policies

• Asset inventories

• Equipment maintenance records

• System backup logs

• Change management information

• Business continuity and incident response plans

Conducting a gap analysis

The SOC 2 gap analysis can help you reveal security issues or shortcomings that need to be addressed. If done when preparing for an audit, you can address and fix problems before the audit.

Some activities you may perform in your gap analysis include:

• Interviewing employees

• Modifying workflows

• Implementing controls

• Training employees on controls

• Updating control documentation 

The gap analysis step can save you time and ensure your systems are addressing the right TSC principles and scope of your audit. Plus, you can create a plan to fix any gaps. 

Developing and implementing policies and procedures

During this phase, you can develop and implement new policies and procedures that address the issues revealed in your gap analysis or update existing policies, so they are compliant.

The specific policies you need to address will depend on the results of your gap analysis (and, ultimately, your audit) and the scope of your audit. 

Some policies commonly assessed include:

• Access control policy

• Acceptable use policy

• Change management policy

• Business continuity policy

• Encryption policy

• Information security policy

• Disaster recovery policy

• Remote access policy

• And more

Establishing a risk management process

Once you’ve identified and assessed your risks, you’ll want to establish a risk management process. 

This process helps you actively manage and design a plan to address the identified risks. This could include steps such as establishing a daily data backup, hosting in multiple zones, or the level of system performance monitoring. 

You’ll want to have an understanding of the categorization of risks, the likelihood and impact, and clear documentation of the process, procedures, and framework that will be followed.

Creating an incident response plan

An incident response plan helps you handle a data breach efficiently and quickly — white minimize any damage from the breach.

The incident response plan will clearly detail:

• How teams communicate IT and security requirements

• The responsibilities and objectives of the organization

• How the organization establishes security controls (including clear connection to policies and procedures)

• Assign duties

• Show how the organization will handle system vulnerabilities, detect issues, and respond to an incident

Enhancing employee training and awareness programs

Security awareness training is a key part of SOC 2 compliance, but what it specifically entails for your organization will depend on your goals, scope, and what you do.

When setting up or enhancing your existing employee training and awareness programs, you’ll want ensure that:

• Every employee within the scope of the training must complete it

• The programs cover security concepts critical to your business, practices, and policies

• The programs must be completed yearly

Remediation of identified gaps and security issues

During the whole process, you’ll want to address any gaps or security issues that arise. One way to identify any additional gaps or to pre-evaluate new systems, policies, trainings, or documentation put into place is to conduct a final readiness assessment.

This step can help you identify any remaining problems or weaknesses which you can fix before completing the official audit. 

How to maintain SOC 2 Compliance

Once you’ve achieved compliance, you’ll need to maintain it.

Here are steps you can take to make maintaining your SOC 2 Compliance simple and straightforward.

Monitoring and reviewing internal policies and procedures

You’ll want to regularly monitor and review your policies and procedures to ensure they don’t need updating in response to anything new within your business or industry. Additionally, changes may need to be made if you change vendors, the structure of your company, where information is stored, or processes involved in storing your data.

Creating a compliance calendar with dates on when policies and procedures are to be reviewed can ensure you’re reviewing information as scheduled and that it gets completed. You can even set automated reminders to alert people of upcoming tasks.

Conducting regular risk assessments

You’ll want to set up regular risk assessments to ensure no changes are needed to your current approach. How frequently you’ll want to conduct these assessments will depend on your organization, needs, and growth. 

For instance, if you’re entering a growth stage you may want to conduct a risk assessment sooner than initially planned to ensure your current risk management processes are still sufficient. That said, all companies should do this at least once a year. 

Continuous improvement of security controls

Your audit likely helped ensure you had a secure baseline of security controls. However, to maintain compliance, you’ll want to monitor and improve controls as needed.

This step can involve rechecking systems to ensure they remain in compliance. How frequently you check depends on things like how critical the system is and the size of the data center. For instance, you may have systems that require weekly reviews if they are critical, while others may only need to be reviewed on a monthly schedule.

If any changes are made, you’ll want to document them and include them in the process.

Regular employee training and awareness programs

To ensure employees are up-to-date with policies and practices, you’ll need to have regular training and awareness programs. These should be tailored to your organization’s specific needs. 

Typically, employees will need to renew most trainings and programs annually.

Preparing for annual SOC 2 audits

Taking the steps to regularly monitor your systems, policies, and trainings will help you be prepared for annual SOC 2 audits. 

Be sure you and your team are updating documentation and policy changes as you go. Because if you didn’t document it, you can’t prove it happened. 

Ideally, you’ll want to set up systems, automations, and routines that help you maintain your compliance and documentation so preparing for your annual SOC 2 audit goes smoothly.