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Four Frequently Asked Questions About SOC 2

If you’re considering a SOC 2 assessment for your organization, you likely have questions about the process, what’s involved, and how to start preparing. SOC 2 (Service Organization Control 2) reports provide assurance to your clients and stakeholders that you have implemented controls to protect their data and ensure the security, availability, processing integrity, confidentiality, and privacy of their information. In this blog post, we’ll address our top four frequently asked questions to help you navigate the SOC 2 landscape with confidence.

1. Can I do a SOC 2 Type 1 and Type 2 assessment together?

Absolutely! It is possible to conduct a combined SOC 2 Type 1 and Type 2 assessment. This approach allows you to assess both the design and operating effectiveness of your controls in a single engagement. The Type 1 component evaluates your control design at a specific point in time, while the Type 2 component builds upon the Type 1 by evaluating the effectiveness of those controls over a specified period. By opting for a combined assessment, you can streamline the process and save time.

2. What happens if my SOC 2 Type 2 report identifies deficiencies? What is the process and timeline for remediation? Do I have to have another full assessment? Do I have to wait a year?

If your SOC 2 Type 2 report identifies deficiencies in your controls, don’t panic. It is common for organizations to have some control gaps or deficiencies during their first SOC 2 assessment. The next step is to focus on remediation efforts to address these identified deficiencies. The timeline for remediation will depend on the severity of the issues and the complexity of the required remediation.

To demonstrate that the controls are operating effectively, you have the option to engage your assessor for a partial or full retest of the remediated controls. There is no need to wait a year for retesting; it can be done as soon as the deficiencies are addressed. However, it’s important to keep in mind that the SOC 2 report covers a specific period, typically 12 months, so ideally, the controls should be operating effectively throughout that period to achieve a positive report.

3. What if there are significant changes to my organization, like a merger or acquisition? What are the next best steps for updating my SOC 2 Type 2 attestation?

Significant changes to your organization, such as a merger or acquisition, require a reassessment of the control environment. In these cases, it may be necessary to conduct a new SOC 2 Type 2 assessment that considers the updated post-merger or post-acquisition environment. This means evaluating the systems, processes, and controls of the acquired entity to ensure they meet the SOC 2 requirements.

It’s crucial to work closely with your assessor to determine the best approach based on the specifics of the merger or acquisition. They will guide you through the process and help you navigate the assessment requirements in light of the organizational changes.

4. If I need both a SOC 2 Type 2 report and an assessment regarding adherence to the HIPAA Security Rule (and Privacy Rule), how much do these assessments overlap? Is there significant cost savings in performing them at the same time, and can an assessor perform both of these types of engagements?

If you require both a SOC 2 Type 2 report and an assessment of adherence to the HIPAA Security Rule (and Privacy Rule), there is indeed some overlap between the two assessments. Both SOC 2 and HIPAA assessments focus on administrative, physical, and technical safeguards. This overlap allows for efficiencies in terms of time and cost, as certain testing procedures can cover requirements from both assessments.

It’s also worth noting that many assessors are equipped to perform both SOC 2 and HIPAA assessments, so it’s absolutely possible for a single firm to do both. Just make sure they have the necessary qualifications and experience to do so. Keep in mind, however, that while there is overlap, there are also unique aspects to each assessment, so be prepared for specific requirements and considerations for each assessment.

SOC 2 assessments and reports play a crucial role in providing trust and confidence to your clients and stakeholders. By understanding the intricacies and addressing common questions, you can navigate the SOC 2 journey smoothly. Remember to work closely with your assessor, keep track of remediation efforts, and leverage the opportunity to streamline assessments when possible. With a well-executed SOC 2 strategy, you can demonstrate your commitment to data security and meet the expectations of your clients and industry regulators.

The HITRUST r2 framework is designed to be comprehensive, and this scoping factor is a perfect example of that design philosophy. It forces you to think beyond firewalls and IAM policies and consider the full environment in which your systems operate. For organizations in leased commercial office space, that environment includes a landlord, a property management company, a cleaning crew, a fire marshal, a building security team, and a building full of mechanical systems you don’t control.

The question isn’t whether you can justify answering “No.” The question is whether your control environment genuinely supports that answer and whether you can prove it to an assessor who’s going to walk your halls, try your door handles, peek into your wiring closets, and ask you who else has a key.

Get this scoping factor right, and you build a foundation of credibility that carries through the rest of your assessment. Get it wrong, and you spend the rest of the engagement explaining why your scoping doesn’t match reality.

Start with the building. The rest follows from there.

SME Highlight

Steve Meyer, CCSFP, CHQP

Steve Meyer is the Senior Director of Consulting Services at Clearwater, bringing over 37 years of experience across various aspects of Information Technology to Clearwater customers. Steve leads the HITRUST Assessment Services team.

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