Achieving System and Organization Controls 2 (SOC 2) compliance is a critical milestone for any organization handling sensitive customer data. It not only demonstrates a commitment to security but also builds trust with clients and partners. However, the journey to SOC 2 compliance is not without its challenges. Compliance teams often encounter hurdles that can delay or complicate the process.

In this blog, we’ll explore the top ten challenges compliance teams face during SOC 2 implementation and provide actionable strategies to overcome them. Whether you’re just beginning your SOC 2 journey or looking to maintain your compliance, these insights will help you navigate the complexities of SOC 2 with confidence.

What is SOC 2 compliance?

SOC 2 is a compliance framework developed by the American Institute of Certified Public Accountants (AICPA) to help organizations demonstrate their ability to manage and protect customer data. 

It focuses on five key Trust Services Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy.

Achieving SOC 2 compliance involves implementing and maintaining a robust set of security controls that align with these criteria, followed by an audit conducted by an independent third-party auditor. 

The outcome of this audit is a SOC 2 report, which serves as evidence that your organization is effectively safeguarding data and mitigating risks. This report is crucial for building trust with customers, prospects, and partners, showing them that your organization takes information security seriously.

Read also: 9 easy steps to review a vendor’s SOC 2 report

10 common SOC 2 compliance challenges

Navigating SOC 2 compliance can be tricky, with several challenges that can derail even the most well-prepared teams. In this section, we’ll explore ten common SOC 2 compliance challenges and provide practical solutions to help you overcome them efficiently.

Challenge #1: Scoping the SOC 2 audit correctly

One of the first and most critical steps in the SOC 2 process is determining the scope of your audit. Getting this wrong can lead to significant issues down the line, such as unnecessary costs, extended timelines, and even failed audits. Scoping involves identifying which systems, processes, and data need to be covered by the SOC 2 audit, and this can be particularly challenging for organizations with complex infrastructures.

For example, if you underestimate the scope, you might exclude critical systems that should be audited, leading to non-compliance. On the other hand, overestimating the scope can cause you to spend resources on areas that aren’t relevant, increasing the time and cost of your audit.

Read also: How to turn SOC 2 compliance into a growth strategy?

Solution

To effectively scope your SOC 2 audit, start by mapping out your entire IT environment and identifying where your customer data resides. This includes cloud services, on-premises servers, and third-party vendors. Engage with key stakeholders from various departments, such as IT, HR, and legal, to ensure that no critical component is overlooked.

Use the Trust Services Criteria (TSC) as a guide to determine which areas of your environment are relevant to the audit. Once you’ve identified the relevant areas, work closely with your auditor to validate the scope before proceeding.

Challenge #2: Implementing and testing security controls

Implementing the necessary security controls to meet SOC 2 requirements is another major hurdle. The controls need to be tailored to your organization’s specific needs and thoroughly tested to ensure they are effective. This process can be time-consuming and resource-intensive, especially for organizations that have never undergone a SOC 2 audit before.

Moreover, the challenge doesn’t end with implementation. You must continuously test these controls to ensure they remain effective over time. Compliance teams often struggle with maintaining the rigor needed to test and document controls regularly, which is essential for passing the audit.

Read also: SOC 2 vs SOC 3: Key differences

Solution

Start by performing a gap analysis to identify which controls you already have in place and which ones you need to implement. Tools like automated compliance platforms can be invaluable here, helping you map out existing controls against SOC 2 requirements and highlighting any gaps.

Once your controls are implemented, establish a regular testing schedule. This can be done through internal audits, automated monitoring tools, or a combination of both. Document every test and its results meticulously—auditors will want to see evidence that your controls are not only implemented but also functioning as intended.

Challenge #3: Managing third-party risks

In today’s interconnected world, no organization operates in a vacuum. Many rely on third-party vendors for critical services, from cloud storage to customer support. 

However, these vendors can also introduce significant risks, particularly if they have access to your sensitive data or systems. Ensuring that your third-party vendors comply with SOC 2 requirements is crucial, yet managing this aspect can be a daunting task.

Third-party risk management involves assessing the security practices of your vendors, ensuring they meet SOC 2 standards, and continuously monitoring them for compliance. Failure to do so can lead to gaps in your security posture and, ultimately, a failed SOC 2 audit.

Solution

Begin by conducting a thorough risk assessment of all third-party vendors, focusing on those with access to sensitive data or critical systems. Request their SOC 2 reports or other relevant certifications to assess their security posture. If a vendor does not have a SOC 2 report, you may need to perform a detailed audit of their security practices or reconsider your relationship with them.

Additionally, include specific clauses in your vendor contracts that require them to maintain SOC 2 compliance and notify you of any security incidents. Regularly review and update these contracts as needed.

Choozle efficiently tracked the compliance status of their sub-vendors using Scrut’s in-built TPRM.

Challenge #4: Aligning internal policies with SOC 2 requirements

One of the overlooked aspects of SOC 2 compliance is ensuring that your internal policies align with the SOC 2 Trust Services Criteria. Many organizations have existing policies that may not fully meet SOC 2 requirements, leading to gaps during the audit process.

Solution

Conduct a thorough review of your current policies to identify any discrepancies with SOC 2 requirements. This includes policies related to data security, incident response, access controls, and more. Engage with a SOC 2 consultant, if necessary, to help align your policies with the framework. Regularly update your policies to reflect any changes in your operational environment or the SOC 2 criteria. Scrut has an automated policy builder that can help you customize your policies to align with the SOC 2 Trust Services Criteria. Schedule a demo with us to learn more.

Challenge #5: Maintaining continuous compliance

Achieving SOC 2 compliance is not a one-time effort; it requires ongoing maintenance. Compliance teams often struggle to maintain the same level of diligence after the audit is complete. Without continuous monitoring and regular updates to controls and policies, organizations can quickly fall out of compliance, putting them at risk for security breaches and failed audits in the future.

Maintaining continuous compliance involves not only keeping your controls up-to-date but also staying informed about changes in the SOC 2 framework and evolving threats to your security infrastructure.

Solution

Establish a culture of continuous compliance within your organization. This starts with regular training and awareness programs for all employees, ensuring that everyone understands the importance of SOC 2 compliance and their role in maintaining it.

Implement a continuous monitoring solution that provides real-time insights into your compliance status. This should include automated alerts for any changes or gaps in your controls, allowing you to address issues before they become significant problems.

Regularly review and update your SOC 2 policies and controls to ensure they remain aligned with industry best practices and evolving regulatory requirements. This should be part of a broader risk management strategy that includes regular internal audits and risk assessments.

Challenge #6:  Collecting and organizing evidence

Evidence collection is a critical part of the SOC 2 audit process. Auditors will request a wide range of documentation, including policies, procedures, and logs, to verify that your controls are operating effectively. Collecting and organizing this evidence can be a logistical nightmare, particularly for large organizations with complex environments.

The challenge is not just about gathering the right documents but also ensuring they are up-to-date and properly formatted. Inconsistent or outdated evidence can lead to delays or even cause your audit to fail.

Solution

To streamline the evidence collection process, start by creating a centralized repository for all SOC 2-related documentation. This could be a secure cloud-based platform where all relevant documents are stored, categorized, and regularly updated.

Use automated tools to collect evidence whenever possible. Many security platforms can automatically generate logs, reports, and other evidence needed for SOC 2 compliance. Ensure that your evidence is reviewed and updated regularly—set reminders for key personnel to update their documentation before the audit begins.

Scrut’s evidence tracker enabled Cogniquest to reduce up to 70% manual burden in evidence collection,

Challenge #7: Training and awareness

Compliance is not just the responsibility of the IT or compliance teams; it requires organization-wide participation. However, creating and maintaining awareness about SOC 2 requirements across the organization can be challenging.

Solution

Implement a comprehensive training program that educates all employees about SOC 2 compliance, their role in maintaining it, and the potential risks of non-compliance. Use engaging methods like workshops, online courses, and real-life scenarios to reinforce the importance of compliance.

Challenge #8: Handling resource constraints

Achieving and maintaining SOC 2 compliance can be resource-intensive, particularly for smaller organizations. Compliance efforts may require additional personnel, tools, and time, which can strain resources.

Solution

Prioritize your SOC 2 efforts by focusing on the most critical areas first. Consider leveraging automated compliance tools that can reduce the manual workload. Outsource certain aspects of the compliance process, such as internal audits or policy development, to experienced consultants if in-house resources are limited.

Challenge #9: Adapting to changes in the SOC 2 framework

The SOC 2 framework evolves over time to meet standards around changes in technology and security threats. Organizations must stay up-to-date with these changes to maintain compliance, which can be challenging.

Solution

Establish a process for staying informed about updates to the SOC 2 framework. Subscribe to relevant industry newsletters, attend webinars, and engage with SOC 2 auditors regularly to understand the implications of any changes. Update your controls, policies, and procedures as necessary to stay compliant with the latest requirements.

Example: An e-commerce company might revise its data retention policy in response to new guidelines on data privacy within the SOC 2 framework, ensuring continued compliance.

Challenge #10: Managing documentation and evidence collection for multiple audits

For organizations that undergo multiple audits, managing documentation and evidence collection across various compliance frameworks can be overwhelming. The requirements for SOC 2 might overlap with other standards like ISO 27001 or HIPAA, leading to redundant efforts.

Solution

Implement a unified compliance management system that allows you to map controls across multiple frameworks. This way, you can streamline documentation and evidence collection, ensuring that efforts for one audit contribute to others. This reduces duplication of work and ensures consistency across all compliance activities.

Read also: How Scrut modernized GRC for Balboa Travel

Conclusion

SOC 2 compliance is a critical aspect of any organization’s security strategy, particularly for those handling sensitive customer data. While the journey to compliance can be challenging, understanding and addressing the common obstacles can significantly ease the process. 

By scoping your audit correctly, implementing and testing the right controls, managing third-party risks, collecting and organizing evidence efficiently, and maintaining continuous compliance, your organization can not only achieve SOC 2 certification, but also build a robust security posture that earns the trust of your customers, partners, and stakeholders.

Remember, SOC 2 compliance is not just about passing an audit; it’s about creating a culture of security and trust within your organization. By overcoming these challenges, you position your company as a trusted partner in today’s increasingly complex digital landscape.

Scrut’s prebuilt controls and continuous monitoring can simplify your SOC 2 compliance journey. Want to see how we can make compliance effortless for your organization? Schedule a demo today!

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