Privacy Assurance with SOC 2
The SOC 2 compliance report provides an assurance to the internal and external stakeholders of the organization, the specific controls implemented, and/or operating effectively for complying with privacy regulatory requirements. A single SOC 2 report can provide information about the organization’s controls over PII data based on the AICPA’s Privacy Category of the Trust Services Criteria and, any specific privacy requirements.
The SOC 2 can provide service organizations the ability to increase transparency and communicate through a single deliverable to customers, business partners, and stakeholders both in and outside the organization. Organizations should also demand a SOC 2 report from their business associates, CSP’s, and other third parties or vendors to understand and to have an assurance over the controls implemented and operating effectiveness of the relevant controls covering Privacy.
Trust Services Category for Privacy
SOC 2 uses the AICPA Trust Services Criteria (TSC) for Privacy Category. These were formerly covered as the Generally Accepted Privacy Principles(GAPP) by AICPA. With, approximately 50 points of focus, the TSC organizes the privacy category as:
- Notice and communication of objectives—The entity provides notice to data subjects about its objectives related to privacy.
- Choice and consent—The entity communicates choices available regarding the collection, use, retention, disclosure and disposal of personal information to data subjects.
- Collection—The entity collects personal information to meet its objectives related to privacy.
- Use, retention and disposal—The entity limits the use, retention and disposal of personal information to meet its objectives related to privacy.
- Access—The entity provides data subjects with access to their personal information for review and correction (including updates) to meet its objectives related to privacy.
- Disclosure and notification—The entity discloses personal information, with the consent of the data subjects, to meet its objectives related to privacy. Notification of breaches and incidents is provided to affected data subjects, regulators and others to meet its objectives related to privacy.
- Quality—The entity collects and maintains accurate, up-to-date, complete and relevant personal information to meet its objectives related to privacy.
- Monitoring and enforcement—The entity monitors compliance to meet its objectives related to privacy, including procedures to address privacy-related inquiries, complaints and disputes.
Aside from the Trust Services Category Privacy Controls, any specific privacy mandates can also be covered. It is important to note that in 2020 AICPA updated its Generally Accepted Privacy Principles(GAPP) into the new Privacy Management Framework (PMF) which is aligned to the Trust Services Privacy Category.
SOC 2 Type 2 for Privacy Benefits
- SOC 2 Type 2 can cover the entire year and the effectiveness of the controls in place.
- It is a Third-Party Period- of-Time assessment and so has Accountability.
- Most other assurance programs or audits are only, at a point in time.
- Since it is a period assessment, it is more like a continuous compliance with low risk and high reliability. It also provides assurance on operative effectiveness of controls
- Comprehensive Framework for Privacy by AICPA.
- Provides a high reliability SOC 2 Seal by AICPA.
- SOC 2 Provides better visibility with detailed controls in the report in contrast to ISO 27001, ISO 27701 standard that provides just a certificate.
- More on SOC 2 vs ISO 27701 PIMS.
- More on SOC Reporting Services.