SOC 2 Compliance: Your Key Stakeholders
Your pursuit of SOC 2 compliance is intended to deliver multiple benefits to your business and its operations. Your compliance efforts must include representation of and participation by the teams and roles most critical to your business. Based on guidance from auditors and experienced compliance managers, here are seven sets of key stakeholders you must make sure to include.
Your HR person or team. Two of the five Trust Services Criteria (TSC) upon which SOC 2 requirements are based are Confidentiality and Privacy. In addition, multiple SOC 2 controls address specific HR-related issues, from onboarding and termination to employee manuals. Therefore, you must ensure your HR policies, procedures, and processes are adequately documented and include measures for enforcement that align with SOC 2 requirements.
Your IT leader(s) and practitioners. All five of the TSC – Security, Availability, Processing Integrity, Confidentiality, and Privacy – specifically address elements of your IT environment and its management. This means almost all the core SOC 2 controls affect or are affected by IT. Whether your IT environment is managed internally or by outside help, you and your IT team must work closely with your auditor to ensure that your IT environment remains “audit-ready” and fully SOC 2 compliant.
Fortunately, depending on your business and the current state of your policies, procedures, and processes, you may not need to address controls for all five of the TSC. For example, while every company must address Security, some or all four of the others may be optional for your company. (For more on this, see “SOC 2 Compliance: Q&A with an Audit Expert – David Barton.”)
Your legal representative(s). Regulations focused on Security, Confidentiality, and Privacy are growing in number and severity worldwide. A single successful cybersecurity breach can cause massive damage to your business’ finances, operations, and reputation. Therefore, you and your legal team must work closely together to ensure your company is compliant with all relevant regulations while you pursue SOC 2 compliance.
Your finance and business operations leader(s). While SOC 2 focuses primarily on protecting personal and proprietary information, SOC 1 focuses on the internal controls relevant to a company’s financial reporting. And your SOC 2 audit preparation efforts are likely to affect some of your organization’s financial and operational policies, procedures, and processes. Your financial and operations personnel may not need to be actively involved in every phase of your SOC 2 journey. However, you must keep them informed of developments relevant to their roles and solicit their input and feedback wherever you think it may help.
Your executive leadership. To be of maximum business value, SOC 2 compliance must be led and championed “from the top.” This means your “C-suite” must be engaged and committed, and must encourage and require the support of your compliance efforts across your entire company. Executive leadership must also be kept informed about the state of your organization’s SOC 2 compliance, especially as audits approach and occur and in the wake of cybersecurity threats and other compliance-challenging events.
Your board of directors. Your directors are fiduciaries. This means they have specific responsibilities to act in your company’s best interests, especially but not exclusively financially. A growing number of lawsuits seek to hold directors personally responsible and liable when their companies suffer cybersecurity breaches. You must ensure your board recognizes that they could be threatened by such lawsuits, and that SOC 2 compliance can help protect them as well as your company.
Your customers and partners. Collectively, your customers and partners are arguably your most critical constituency. They all demand and expect your business to be trustworthy, and SOC 2 compliance is an increasingly popular declaration of trustworthiness. Therefore, your SOC 2 journey must incorporate input and support from all the other constituencies highlighted above to maximize that trustworthiness and minimize risk for your business, customers, and partners.