SOC 2 Type II reveals the degree to which your security controls actually function over the course of a single day. Type I is the simpler of the two.
At a particular instant in time, it communicates to the world that your controls have been built appropriately. Type II demonstrates that said controls were adhered to in a consistent manner over a period of several months. This is when businesses find themselves in a difficult situation.
My experience of working directly with engineering teams, founders, and security leaders in a variety of regions over the course of twenty years has allowed me to recognize consistent patterns.
SOC 2 is challenging, however the majority of enterprises do not fail because of it. The reason they are unsuccessful is that they fail to see how operational the Type II audit actually is.
It is important to have a thorough awareness of these common mistakes in order to avoid painful rework in the future.
This is especially true if you are planning for SOC 2 compliance or determining whether you should begin with Type I or move directly into Type II.
One approach is to consider Type II to be an extended form of Type I.
There are a lot of teams that think Type II is just additional documentation. No, it is not.
For Type II, it is necessary to collect living evidence during the entirety of the audit period. Logs, reviews, approvals, monitoring data, onboarding and offboarding trails, and incident handling must all demonstrate consistent behavior over the course of time.
How to stay away from it
Create a routine in which each key control operates according to the schedule.
Avoid putting everything away until the very end. It is constancy, not last-minute effort, that is rewarded in Type II.
In addition to this, using a professional SOC 2 audit consultancy is beneficial. If you have a reliable consulting partner, they will walk you through the tasks that need to be recorded each month so that you do not end up with surprises in the future.
The ownership of control is not defined.
The policies are documented, but no one is specifically responsible for carrying them out with that responsibility. This becomes instantly apparent while the audit is being conducted. The auditor is interested in determining who is responsible for each control, who gave their approval, and how consistently it was carried out.
How to stay away from it
Allocate a single owner to each control.
Maintain a straightforward list. By removing the element of uncertainty, ownership helps to lessen audit friction.
The collection of evidence occurs too late
When it comes to missing logs, SOC 2 Type II is quite difficult to work with. The absence of evidence during particular months of the audit window is commonly cited as the most common reason for the failure of businesses.
How to stay away from it
Maintain a steady collection of evidence.
Notes should be set.
Automate the process of collecting logs whenever it is practicable to do so.
For those who are uncertain about which components require evidence on a monthly basis and which just require checks on a periodic basis, a structured comparison of SOC 2 Type I versus Type II can be of assistance. By gaining an understanding of the distinction early on, compliance gaps can be avoided later in the year.
Accidents that occur in access management without anyone noticing
The access controls move in a silent manner. There are still accounts held by former employees. There are several locations that do not support MFA. Credentials that have been shared do not pass. There is a clear manifestation of all of this during Type II.
How to stay away from it
Hold access reviews on a monthly basis.
Put in place a stringent checklist for offboarding.
Keep an eye on the MFA coverage across all of the essential systems.
The documentation of change management is lacking
Although engineers are responsible for pushing changes, there is a lack of documentation regarding approvals, peer reviews, and deployment trails. Type II necessitates not just the modification but also the complete trace surrounding it.
How to stay away from it
Integrate approvals into the process of your GitHub or GitLab account.
Instead of seeing the process as an additional compliance task, make it a part of the culture of the development team.
There are monitoring tools available, but there are no review periods.
Despite the fact that many businesses have effective monitoring and alerting systems, nobody actually analyzes the alerts on a regular basis or documents their replies.
How to stay away from it
Review the alerts on a weekly basis.
Even for relatively minor problems, you should keep an incident response log.
Demonstrate to the auditor that you are able to do more than merely deploy tools.
Beginning Type II before the players are prepared to do so
Teams are frequently forced into Type II prematurely as a result of pressure from clients. When there is a lack of operational maturity, holes become apparent during the auditing process.
How to stay away from it
Proceed with a readiness evaluation.
Before you commit to the full Type II term, you should first conduct a practice audit and address any operational gaps that you find.
The Mavericks, a seasoned SOC 2 consultancy, can make this phase significantly easier to complete because they are able to detect weak areas at an earlier stage and provide teams with guidance on how to correct them.
Final Thoughts
When all of your security operations are running smoothly, achieving SOC 2 Type II is not difficult. Only when teams approach it as a documentation exercise rather than an operational discipline does it become a source of stress.
You might investigate our SOC 2 Audit and Attestation service if you are looking for direction, structure, or hands-on assistance in preparation for SOC 2 Type I or Type II.
It provides an explanation of how the audit is conducted, what you need to do in order to get ready, and how our team can assist you in avoiding the mistakes that bring down the majority of businesses during Type II.
