2021 has been a challenging year for cybersecurity. The shift to remote work models, and to digital tools that automate and streamline processes, brought a rise in cyberattacks worldwide — especially phishing and ransomware attacks, as seen with recent attacks on healthcare facilities and other essential services companies.
Cyberattacks are not new, but technology has expanded so significantly that cyber threats affect more companies than ever. In response to those threats and the harm of data breaches, the American Institute of Certified Public Accountants (AICPA) has developed several compliance standards for data protection and management, including:
- Service Organization Controls 1 (SOC 1)
- SOC 2
- SOC for cybersecurity examinations
The SOC frameworks provide guidelines to companies about the secure handling of sensitive information. Audits performed according to those SOC standards allow a company to gain assurance that a vendor it wants to use has sufficiently strong cybersecurity controls.
A SOC 1 report provides assurance over a vendor’s internal controls for financial reporting. A SOC 2 report provides assurance over the vendor’s cybersecurity controls, based upon the AICPA’s five Trust Service Criteria: confidentiality, availability, security, processing integrity, and privacy. The SOC 2 allows a vendor to demonstrate the robustness of its processes, vendor management effectiveness, and dedication to protecting the data of customers and partners.
SOC 1 and SOC 2 reports can both also have one of two types. A Type I report assesses whether the business has properly designed internal controls at one specific point in time. A Type II report also assesses whether those controls actually work as intended over a longer period of time (usually six months or one year).
There is also the SOC for Cybersecurity report, an attestation of the progress and effectiveness of the entity’s cybersecurity risk management program in the face of ever-changing cyber risks. This SOC report is broader and directed at all stakeholders, whereas SOC 2 is intended for management with specific knowledge about the processes and controls being evaluated.
This article will focus on the relationship between SOC 2 and SOC for Cybersecurity, along with the differences that may favor the use of either to strengthen your organization’s cybersecurity risk management program.
The Relationship Between SOC for Cybersecurity and SOC 2
Although SOC 2 and SOC for Cybersecurity have different purposes and uses, they share similarities in their output and structure. At a high level, both provide objective assurance on an organization’s internal controls for cybersecurity management and information security.
All SOC audits must be performed by an independent CPA (Certified Public Accountant). Both reporting frameworks maintain the components of management’s description of criteria, management’s assertions, and practitioner’s formal opinions.
Also, both cybersecurity frameworks are designed to be used by a wide range of organizations. That said, their application will depend on a company’s specific needs concerning its business partners and clients.
Critical Differences Between SOC for Cybersecurity and SOC 2
There are distinct differences between SOC for Cybersecurity and SOC 2, from their purpose and uses to their audience.
A SOC 2 report assesses data management by third-party service providers and focuses on information security processes for specific business units or services. The SOC for Cybersecurity, on the other hand, evaluates the entire organization’s cybersecurity risk management program.
SOC for Cybersecurity doesn’t have a specific baseline for evaluation and can use any cybersecurity framework already applied by the organization (such as ISO 27001 or the NIST Cybersecurity Framework). SOC 2 is limited to the AICPA’s Trust Service Criteria, which adhere to the COSO frameworks.
The SOC for Cybersecurity is for general use. It has a broad audience, so it is suitable for stakeholders interested in knowing that the entity’s cybersecurity objectives and programs are well-designed. On the other hand, SOC 2 is aimed at active service organization users, with detailed information on information security processes, so its audience is limited and specialized.
Within a SOC for Cybersecurity report, all third-party risks must be considered and evaluated at a high level.
SOC 2 reports are more nuanced. First, determine which third parties are considered “subservice organizations” per the SOC 2 definition. These are third parties whose services help meet your SOC 2 trust services criteria. Typical examples of subservice organizations include cloud hosting services and data centers — you are relying on their internal controls to meet your SOC 2 requirements.
In SOC 2 reports, you must have documentation of due diligence and vendor management processes for all subservice organizations. In some cases, you may also include the actual controls performed by specific sub-service organizations.
A SOC 2 report contains the Trust Services Criteria and the results from the auditor’s tests of controls, so it may collect sensitive information that should only be shared with a specific audience. On the other hand, the SOC for Cybersecurity is more general in scope and intended for a broader audience, so it does not include sensitive data. It could, for example, be posted on your corporate website for all to see.
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