12 Critical SOC 2 Controls to Support Compliance

SOC 2 compliance revolves around a structured framework of Trust Services Criteria and requirements designed to ensure the security and integrity of your systems. These criteria outline high-level goals, while the actionable steps to achieve them are implemented through specific controls.

Designed by Freepik

The criteria and requirements define what you must achieve—such as safeguarding sensitive data or ensuring system availability—while the controls are the how, the practical actions, and mechanisms that make compliance a reality.

In this post, we’ll break down the SOC 2 framework—starting with its foundational structure of criteria and requirements—and then delve into the 12 most critical SOC 2 controls every organization should focus on to achieve and maintain compliance.

How SOC 2 is Structured

Trust Service Categories

The framework revolves around five Trust Service Categories that define the primary areas of focus for SOC 2 compliance. Organizations can select the categories most relevant to their business, but the Security category is mandatory for all SOC 2 audits.

• Security (Mandatory): Ensures systems are safeguarded against unauthorized access, disclosure, or modification. This category underpins the entire SOC 2 framework and includes essential controls like access management, encryption, and incident response.
• Availability: Verifies that systems remain operational and meet service level agreements (SLAs)
• Confidentiality: Protects sensitive or proprietary information from unauthorized disclosure. Encryption, access controls, and secure file-sharing protocols play a key role here.
• Processing Integrity: Ensures systems process data accurately, completely, and as intended. 
• Privacy: Focuses on safeguarding personally identifiable information (PII) 

Each category addresses specific risks and priorities, allowing organizations to tailor their SOC 2 audit to their business needs.

Common Criteria (CC)

At the heart of the SOC 2 framework is the Common Criteria, a set of 33 high-level requirements that form the foundation for the Security category. These criteria establish the objectives that controls must meet and are divided into key areas, such as:

• Governance and Risk Management: Ensures oversight of compliance efforts and identifies potential organizational risks.
• Access Control: Verifies that only authorized personnel can access sensitive systems or data.
• Incident Response: Establishes procedures for detecting, responding to, and recovering from security incidents.
• System Monitoring and Logging: Provides visibility into system activity to detect suspicious behavior.
• Change Management: Ensures that changes to systems or processes are authorized, tested, and documented to prevent errors.

If you choose additional Trust Service Categories beyond Security, the Common Criteria serve as a baseline, with category-specific requirements layered on top. For example, adding the Confidentiality category will include criteria for encrypting sensitive information.

Controls

Controls are the actionable components of SOC 2 compliance—the specific mechanisms, tools, and processes an organization implements to satisfy the Common Criteria and Trust Service Category requirements.

For example:

• Access Controls: Role-based access control (RBAC) supports the Logical Access criteria (CC6.1).
• Encryption: Encrypting sensitive data aligns with Data Protection criteria (CC5.1).
• Monitoring Tools: SIEM systems like Splunk fulfill Monitoring Controls (CC7.2).

Auditors will evaluate not only whether these controls are in place but also how effectively they operate. Controls can be customized to fit the organization’s infrastructure and risk profile, but they must align with the overarching requirements of the Common Criteria and selected Trust Service Categories.

Two Key Types of SOC 2 Reports

• Type 1: Evaluate your controls at a single point in time. It’s a snapshot: “Do you have the right controls in place?”
• Type 2: Assess how your controls perform over time (usually 3–12 months). It’s a deeper dive: “Are your SOC 2 Type 2 controls consistently effective?”

Ready to Tackle the Most Critical Controls?

Now that you understand the framework’s structure let’s dive into the 12 critical SOC 2 controls list every company should start with. These controls are designed to address the Common Criteria and support compliance with the Security Trust Service Criteria—your baseline for protecting systems and data.

List of SOC 2 Controls

1. Role-Based Access Management (RBAC)

How do you ensure only the right people access the right systems? Role-based access management ensures only authorized personnel can access specific systems and data based on their roles and responsibilities. This control aligns with SOC 2 requirements for Logical Access Controls (CC6.1, CC6.2).

To implement RBAC, organizations can define user roles based on job functions, use centralized identity management systems like Okta or Azure AD, and conduct regular access reviews. For example, a financial analyst might only have access to reporting tools but not payroll systems. Regular audits ensure that permissions stay aligned with evolving responsibilities.

2. Multi-Factor Authentication (MFA)

Multi-factor authentication adds an extra layer of security to user authentication, requiring users to verify their identity through two or more factors. This is critical for protecting against credential compromise, a common attack vector. MFA fulfills the Logical Access Controls requirement (CC6.1).

Practical implementation includes requiring MFA to access sensitive systems using tools like Google Authenticator or Duo. Adaptive MFA, which adjusts authentication requirements based on risk factors like location or device, adds an extra layer of protection. For example, employees logging in from a new country might need to verify their identity via a one-time passcode and biometric authentication.

3. Encryption of Data at Rest and in Transit

Encryption protects sensitive data from unauthorized access during storage and transmission. This control addresses SOC 2 requirements for Data Protection (CC5.1, CC5.2).

Organizations can use AES-256 encryption for stored data and TLS 1.3 for data in transit. Sensitive fields in databases, such as social security numbers, should be encrypted, with access to decryption keys tightly controlled. For example, file-sharing protocols like HTTPS or SFTP ensure secure data exchanges with external parties.

4. Incident Response Plan (IRP)

An incident response plan prepares organizations to detect, respond to, and recover from security incidents. This control fulfills the Incident Management requirement (CC7.3).

Creating an IRP involves defining response steps for potential incidents, conducting tabletop exercises to simulate breaches, and deploying tools like Splunk or PagerDuty for alert management. For example, if malware is detected on a server, the IRP should detail containment, eradication, and recovery processes, ensuring minimal downtime.

5. System Monitoring and Logging

Monitoring system activity provides visibility into potential threats and ensures compliance with SOC 2 Monitoring Controls (CC7.2).

Implementation involves deploying Security Information and Event Management (SIEM) tools like Splunk or LogRhythm, enabling detailed audit logs for critical systems, and setting up real-time alerts for suspicious activities. For example, a spike in failed login attempts could trigger an alert for further investigation.

6. Vulnerability Management Program

A vulnerability management program identifies and addresses security weaknesses. This control aligns with Risk Mitigation requirements (CC3.2, CC7.1).

Organizations should schedule regular vulnerability scans, implement a patch management system, and track remediation efforts. For instance, a discovered vulnerability in a web application should be patched within a defined time frame, with all actions documented

7. Data Backup and Recovery

Data backup and recovery ensure that critical information can be restored following a failure or attack. This control supports Availability requirements (CC9.1).

Implementation includes using cloud backup solutions like AWS Backup, defining Recovery Time Objectives (RTOs) and Recovery Point Objectives (RPOs), and regularly testing recovery procedures. For example, backups of financial records should be stored securely in multiple locations to mitigate regional disasters.

8. Risk Assessment Program

A risk assessment program evaluates potential threats to organizational objectives and assets. This control fulfills Risk Assessment requirements (CC3.1, CC3.2).

Organizations can maintain a risk register to document and rank risks, perform annual risk assessments, and implement mitigation strategies. Tools like Centraleyes streamline this process. For example, identifying risks related to third-party integrations might lead to enhanced vendor security evaluations.

9. Security Awareness Training

Security awareness training educates employees on recognizing and preventing threats like phishing and ransomware. This control aligns with Communication and Training requirements (CC1.4).

To implement this, organizations can conduct annual training sessions, use gamified platforms like KnowBe4, and simulate phishing attacks to measure employee response. For example, employees should be able to identify suspicious emails and report them promptly after training.

10. Change Management Controls

Change management ensures that system changes are authorized, tested, and documented. This fulfills the Change Management requirement (CC8.1).

Implementation involves maintaining a formal change request process, conducting peer reviews, and using version control tools like GitHub. For instance, deploying new software features should follow a defined process, including testing in a staging environment before production.

11. Third-Party Vendor Management

Managing third-party vendors reduces risks introduced by external partners. This control addresses Risk Management requirements (CC3.4).

Organizations can require SOC 2 reports or equivalent vendor certifications, conduct regular risk assessments, and use platforms like OneTrust for vendor management. For example, evaluating a vendor’s security practices ensures that their systems align with organizational standards.

12. Physical Security Controls

Physical SOC 2 security controls protect data centers and sensitive environments. This control aligns with Physical Access requirements (CC6.7).

Practical measures include using biometric scanners, access badges, and surveillance systems, as well as logging and auditing physical access. For instance, only authorized personnel should have access to server rooms, with entry logs regularly reviewed.

How to Approach SOC 2

1. Start with Security: All SOC 2 audits include the Security category. This is where you’ll implement foundational controls like access management, encryption, and system monitoring.
2. Build for the Future: Even if you only need Security now, align your processes with other Trust Service Categories. This makes scaling compliance easier as your business grows.
3. Invest in Documentation: Policies, procedures, and evidence are non-negotiable for SOC 2. If it’s not documented, it doesn’t exist.
4. Automate Where Possible: Centraleyes streamlines compliance, helps you manage risks, and automates evidence collection.