Identifying the Scope of SOC 2 (Part 3) - SOC 2 Compliance Journey Series
John Rogers
Co-Founder & Head of Operations
Introduction
Building on our previous discussions from Part 1: Business case for SOC 2 and Part 2: Choosing the right Trust Service Criteria, this guide focuses on the next crucial step.
Defining the scope of SOC 2 to ensure your compliance efforts are both focused and effective.
Defining the Scope of SOC 2
The scope of your SOC 2 compliance journey determines what areas of your organization will be assessed and reported on. Getting this step right ensures your efforts are targeted, meaningful, and aligned with both your organizational goals and customers expectations. Let’s break down the key components and expand on their significance:
Scoping Considerations
Rule of Thumb
When defining your SOC 2 scope, include all systems, vendors, and applications that store, process, or impact customer data security. The goal is to align your compliance efforts with real business risks while maintaining efficiency.
Key Areas to Consider
1. Customer-Facing Systems
These are the systems directly accessed by customers or involved in handling their data. Their security posture directly impacts customer trust and compliance obligations.
Include:
- Primary SaaS platform / customer portal → The main application where customers interact and store data.
- Public APIs and web interfaces → Any exposed endpoints that process customer requests.
- Data storage systems (databases, object storage) → SQL/NoSQL databases, cloud object storage (e.g., AWS S3, Google Cloud Storage).
- Production hosting infrastructure → Cloud platforms (AWS, Azure, GCP) or on-premises servers that host customer data.
Example Risk: A misconfigured API endpoint can expose sensitive customer data to unauthorized access.
2. Internal Systems and Enterprise Applications
These systems support internal operations but may impact SOC 2 compliance if they interact with customer data or production systems.
Include:
- Employee access management tools (Okta, Active Directory) → Control access to production systems.
Example Risk: An overprivileged internal user in the CRM system could access customer PII without proper authorization.
3. Third-Party Services
Your vendors can introduce security risks, so their compliance posture affects yours. Any third party that processes, stores, or transmits customer data should be evaluated.
Include:
- Cloud service providers (AWS, Azure, GCP) → Hosting and storage providers that hold customer data.
- Email & communication platforms (Twilio, Slack) → If they process customer PII or security alerts.
Example Risk: A third-party email provider suffers a data breach, exposing customer invoices containing sensitive financial details.
4. Development and Testing Environments
Even non-production environments can impact compliance if they interact with sensitive data or have access paths to production.
Include:
- Staging & pre-production environments → If they mirror production and contain real customer data.
- CI/CD pipelines (GitHub Actions, Jenkins, GitLab CI/CD) → Automate code deployments and need strict access controls.
- Infrastructure as Code (Terraform, CloudFormation) → Defines cloud resources and security settings.
Example Risk: A misconfigured CI/CD pipeline accidentally deploys sensitive customer data to a publicly accessible test environment.
5. Processes and Resources
Security isn’t just about systems, it’s also about how your people and workflows interact with those systems.
Include:
- Change management processes → How software updates and security patches are deployed (e.g., ITIL, Agile).
- Incident response & monitoring (SOC, SIEM tools like Splunk, Datadog) → How security incidents are detected and managed.
- Internal teams and contractors → Employees, third-party developers, and security teams who access in-scope systems.
Example Risk: A contractor without proper security training gains temporary access to production but doesn’t follow access revocation policies.
Early Stage vs. Scale up vs. Enterprise
Scoping SOC 2 compliance differs based on company size and maturity. Here’s a realistic approach for each company size:
1. Early-Stage Companies (Startups & Small SaaS Providers)
Focus: Minimum viable compliance with Security TSC.
Scope:
- Production environment and customer-facing applications
- Basic access controls and logging
- Vendor management (key third parties)
Common Challenges:
- Limited security personnel
- Lack of formal policies and documentation
Best Approach:
- Use SOC 2 templates for policies
- Automate security monitoring where possible
2. ScaleUp Companies (Growing Mid-Sized Companies)
Focus: Strengthening compliance with additional controls.
Scope:
- Internal IT and security systems
- Customer support platforms
- More robust change management processes
Common Challenges:
- Balancing compliance with growth
- Vendor due diligence as partnerships expand
Best Approach:
- Assign dedicated security/compliance roles
- Conduct regular internal security audits
3. Enterprise
Focus: Comprehensive security and compliance framework.
Scope:
Multi-region data centers and infrastructure
Full supply chain/vendor compliance
Advanced security tools (SIEM, threat intelligence)
Common Challenges:
Complexity of managing global security operations
Integration of multiple security frameworks (SOC 2, ISO 27001, etc.)
Best Approach:
Establish a compliance team
Continuous monitoring and audit readiness
Q1: Which Systems Do Customers Expect to Be in Scope for SOC 2?
Reason: Customers need assurance that their data is processed and stored securely. Including key customer-facing systems ensures transparency and trust.
Use Case:
- SaaS applications where users enter, store, or process data
- APIs and web portals that provide customer access
- Cloud-hosted production environments handling sensitive data
Q2: What About Internal Systems – Should They Be in Scope?
Reason: Internal systems impact security posture and can be an attack vector. Any system with access to production should be considered.
Use Case:
- Employee laptops accessing production systems
- Security monitoring and incident response tools
- Development environments linked to production
Q3: How Do We Handle Third-Party Vendors and Cloud Services?
Reason: Vendors introduce security risks, so their compliance posture affects yours.
Use Case:
- Payment processors handling transactions
- Cloud storage providers hosting customer data
- External security monitoring services
Q4: What About Development and Testing Environments?
Reason: Test environments can introduce risks if they mirror production or contain customer data.
Use Case:
Shared infrastructure between test and production
CI/CD pipelines with deployment permissions
Security testing environments simulating real-world threats
Q5: Which Security Tools Need to Be Included?
Reason: Security tools play a direct role in detecting, preventing, and responding to threats.
Use Case:
SIEM solutions for log monitoring
Identity and access management tools
Vulnerability scanners to identify risks
Q6: What About Backup and Disaster Recovery Systems?
Reason: Data loss or downtime can disrupt business operations and violate customer SLAs.
Use Case:
Cloud backup services storing customer data
- Disaster recovery sites ensuring uptime
- Monitoring tools tracking system availability
FAQs
What are the risks of excluding critical elements such as systems, controls, processes, or personnel from your SOC 2 scope?
- Excluding these items can lead to incomplete assessments, an auditor issuing a disclaimer of opinion, or outright audit failure—ultimately exposing your organization to heightened security and compliance risks.
How often can the SOC 2 scope change, and what drives those changes?
- The SOC 2 scope can evolve annually based on changes in your organization’s systems, processes, or controls, as well as the adoption of new trust criteria or business requirements.
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.