Choosing Relevant Trust Service Criteria (Part 2) - The SOC 2 Compliance Journey
John Rogers
Co-Founder & Head of Operations
Introduction
In Part 1 of this series, we discussed the business case for SOC 2, outlining the key motivations for organizations to embark on the SOC 2 compliance journey. From building client trust to achieving competitive differentiation, Part 1 laid the groundwork for understanding why SOC 2 compliance is essential for the business.
Part 2 will focus on the critical step of selecting the relevant Trust Service Criteria (TSC). These criteria form the backbone of SOC 2 compliance, helping organizations tailor their controls to align with their operational goals, client expectations, and regulatory requirements.
Overview of Trust Service Criteria (TSC)
SOC 2 focuses on the following five principles to evaluate a company’s internal controls:
- Security: Protecting against unauthorized access, both physical and logical.
- Availability: Ensuring that systems are available for operation and use as agreed upon or needed.
- Processing Integrity: Guarantee that system processing is complete, valid, accurate, timely, and authorized.
- Confidentiality: Protecting confidential information from unauthorized access.
- Privacy: Ensuring that personal information is collected, used, retained, and disclosed in conformity with privacy principles.
Key drivers in choosing Trust Service Criteria
Security (Mandatory)
Use Cases: Applicable to nearly all industries, particularly SaaS, where safeguarding customer data is essential.
Reason: This criterion is mandatory for all SOC 2 reports and forms the foundation of SOC 2 compliance. It ensures systems are protected against unauthorized access, unauthorized disclosure of information both physical and logical.
Availability
Use Cases: Highly relevant for SaaS platforms, cloud service providers, and managed service providers, where uptime is a competitive differentiator
Reason: Focuses on ensuring that systems and services are available as agreed in service-level agreements (SLAs). This is crucial for businesses providing 24/7 online services.
Confidentiality
Use Cases: Adopted by industries handling intellectual property, business secrets, or financial data, such as healthcare, finance, and legal sectors.
Reason: Ensures that sensitive or proprietary data is protected from unauthorized access or exposure.
Privacy
Reason: Ensures that personal information is collected, stored, and processed in line with privacy regulations and agreements.
Use Cases: Relevant for companies managing personally identifiable information (PII), such as healthcare SaaS, HR tech, and customer data platforms.
Processing Integrity (Adopted the Least)
Reason: Ensures that systems process data completely, accurately, timely, and validly. This criterion is often industry-specific and not always required.
Use Cases: Predominantly used in financial services or supply chain SaaS platforms where the accuracy of processing transactions or data is critical.
Trust Criteria Adoption Sequence
When organizations pursue SOC 2 compliance, their journey typically starts with the Security criterion (the only mandatory criterion). The addition of Availability and Confidentiality depends on various factors such as the company’s maturity, its growth stage, the demands of its clients, and industry.
Here’s an overview of the typical progression:
Security (Year 1)
When To Start: Organizations typically begin with the Security criterion in their first year of SOC 2 compliance efforts.
Trigger: Early-stage SaaS companies or startups, especially when securing their first few enterprise clients or venture funding.
Availability (Year 2–3)
When To Add: Organizations often include Availability in their SOC 2 scope within 2–3 years after beginning with Security. As companies grow, especially SaaS providers, uptime and service-level agreements (SLAs) become critical to clients. Including Availability demonstrates a commitment to reliable and consistent service delivery.
Trigger: As mid-sized SaaS companies grow and expand into enterprise markets, they will start to provide mission-critical applications or services for their customers. Customers then require high system uptime and high performance to support their needs.
Privacy (Year 2–3)
When To Add: Companies often integrate Privacy into their SOC 2 scope within 2–3 years as they continue to expand their customer base. This step becomes essential in industries like healthcare, finance, or SaaS applications, where organizations handle sensitive personal data. By incorporating Privacy, it demonstrates a proactive commitment to safeguarding personal data in compliance with laws like GDPR or CCPA.
Trigger: When businesses expand into regions with stringent privacy regulations, such as the EU (GDPR) or California (CCPA), they must incorporate Privacy. Customers in highly regulated industries may also demand evidence of robust data protection practices. In both scenarios, whether your product offering involves sensitive personal data or analyzes user data, Privacy builds customer confidence by showing that you handle their data responsibly.
Confidentiality (Year 3–5):
When To Add: Confidentiality is often added in the third to fifth year. Once companies start handling significant amounts of sensitive or proprietary client data, Confidentiality is required. This criterion protects sensitive information like intellectual property, customer data, or financial records.
Trigger: When serving highly regulated industries like healthcare, finance, or legal, Confidentiality helps address contractual requirements to safeguard proprietary client data. SaaS companies offering analytics, HR solutions, or other data-driven services often have these requirements.
Process Integrity (Adopted the Least):
When To Add: Process Integrity is introduced into the SOC 2 framework as organizations continue to mature and wish to showcase the reliability of their systems processing capabilities. This is crucial for businesses handling transactional data or critical workflows, such as payment processors, logistics, or automated decision-making platforms.
Trigger: Integrating complex automated systems creates the need for robust validation and integrity controls. Process integrity helps with strict processing reliability requirements when expanding into fintech, healthcare or similar industries. By adopting this into your SOC 2 framework, companies can grow into enterprise-level partnerships where accurate and complete data processing is essential.
TLDR: SOC 2 Timeline for a SaaS Company
- Year 1: Start with Security to meet initial client demands.
- Year 2–3: Add Availability as contracts require guarantees on uptime and performance.
- Year 3–5: Add Confidentiality as clients share proprietary or sensitive data, particularly in industries like healthcare or finance.
This phased approach ensures organizations align their SOC 2 efforts with business priorities and client expectations.
Ready to take the next step on your SOC 2 compliance journey?
Ready to elevate your business’s security and compliance game? Dive into the SOC 2 Trust Services Criteria and discover exactly what your business needs to build trust with clients and stakeholders. Learn how aligning these principles with your business can set them apart in today’s competitive landscape.
Don’t wait start your journey to SOC 2 readiness with Prokopto.