SOC 27 min read

Maintaining SOC 2 Compliance Year Over Year

Achieving SOC 2 is just the beginning. Maintaining compliance year after year requires ongoing effort, but it doesn't have to be painful. This guide covers how to sustain your SOC 2 program efficiently.

Key Takeaways

Point Summary
Annual cycle Q1: Review & Planning → Q2-Q3: Operations & Monitoring → Q4: Audit Preparation
Quarterly tasks Access reviews, training tracking, vendor reviews, evidence freshness checks
Continuous monitoring Security events 24/7, availability monitoring, configuration change detection
Year 2+ effort Significantly reduced compared to Year 1, especially with a managed approach
Key metrics Control effectiveness >95%, access reviews 100%, training completion 100%

Quick Answer: SOC 2 maintenance requires quarterly access reviews, continuous evidence collection, and annual policy updates. With a managed service approach, Year 2+ becomes much more streamlined. Most of the heavy lifting is handled through automated monitoring and ongoing support.

The SOC 2 Lifecycle

Annual Compliance Cycle

Audit Month (Year 1 & 2+)

Q1: Review & Planning

  • Post-audit review
  • Update plans
  • Policy refresh
  • Training schedule

Q2-Q3: Ops & Monitoring

  • Continuous monitoring
  • Evidence collection
  • Control execution

Q4: Prep for Renewal

  • Pre-audit assessment
  • Gap closure
  • Auditor prep
  • Evidence finalization

Quarterly Maintenance Tasks

Q1: Review and Planning (Post-Audit)

Audit Debrief

  • Review audit findings and exceptions
  • Document lessons learned
  • Create remediation plan for any issues
  • Update controls based on feedback

Annual Planning

  • Set compliance objectives for the year
  • Plan policy review schedule
  • Schedule quarterly access reviews
  • Plan training calendar
  • Budget for upcoming audit

Policy Updates

  • Review Information Security Policy
  • Update policies for any organizational changes
  • Communicate policy changes to employees
  • Collect new policy acknowledgments

Q2: Operations and Monitoring

Access Management

  • Conduct Q1 access review
  • Review privileged access
  • Audit dormant accounts
  • Verify MFA compliance

Training

  • Ensure new hire training completion
  • Launch annual security awareness training
  • Track training completion rates

Vendor Management

  • Review critical vendor security
  • Update vendor inventory
  • Collect new vendor SOC reports
  • Assess any new vendors

Documentation

  • Update system description for changes
  • Document any infrastructure changes
  • Update data flow diagrams if needed

Q3: Operations and Monitoring (Continued)

Access Management

  • Conduct Q2 access review
  • Address any access issues identified
  • Review service account access

Security Operations

  • Review security monitoring effectiveness
  • Conduct tabletop incident response exercise
  • Review vulnerability management metrics
  • Ensure penetration test is scheduled

Business Continuity

  • Review BC/DR plans
  • Conduct DR testing
  • Verify backup testing results
  • Update recovery procedures if needed

Mid-Year Check

  • Review compliance posture
  • Identify any emerging gaps
  • Plan remediation for Q4 if needed

Q4: Audit Preparation

Pre-Audit Assessment

  • Conduct internal readiness assessment
  • Review all evidence for completeness
  • Address any identified gaps
  • Verify all recurring controls are documented

Access Management

  • Conduct Q3 access review
  • Final review of privileged access
  • Verify all terminations processed correctly

Documentation Finalization

  • Finalize policy updates
  • Complete any outstanding acknowledgments
  • Ensure training records are complete
  • Verify vendor documentation is current

Auditor Coordination

  • Confirm audit dates
  • Prepare population lists
  • Stage evidence in auditor portal
  • Brief team on audit process

Continuous Monitoring Requirements

Real-Time Monitoring

Area Monitoring Requirement
Security Events 24/7 alerting for critical events
System Availability Uptime monitoring with alerts
Access Changes Alerts on privileged access changes
Configuration Changes Detect unauthorized changes
Vulnerability Status Continuous scan results

Periodic Reviews

Review Frequency Owner
Access Reviews Quarterly IT/Security
Vulnerability Review Weekly/Monthly Security
Policy Review Annual Security/Legal
Risk Assessment Annual Security
Vendor Review Annual (critical: quarterly) Security
BC/DR Testing Annual IT/Operations

Common Year 2+ Challenges

Challenge 1: Compliance Fatigue

Symptoms:

  • Controls start slipping
  • Documentation becomes outdated
  • Team loses focus on compliance

Solutions:

  • Automate everything possible
  • Integrate compliance into daily workflows
  • Celebrate compliance wins
  • Make security everyone's responsibility

Challenge 2: Organizational Changes

Symptoms:

  • New systems not properly assessed
  • Departed employees still have access
  • Policies don't reflect current practices

Solutions:

  • Integrate security into change management
  • Automate onboarding/offboarding
  • Regular policy-practice alignment reviews
  • Quarterly scope reviews

Challenge 3: Control Drift

Symptoms:

  • Controls operate differently than documented
  • Evidence doesn't match policy
  • Audit findings increase

Solutions:

  • Continuous monitoring and alerting
  • Regular control testing
  • Periodic self-assessments
  • Address drift immediately

Challenge 4: Evidence Staleness

Symptoms:

  • Evidence from previous year
  • Gaps in continuous evidence
  • Scramble before audit

Solutions:

  • Automated evidence collection
  • Monthly evidence freshness checks
  • Continuous monitoring platform
  • Year-round evidence hygiene

Challenge 5: Expanding Scope

Symptoms:

  • New products/services not covered
  • Customers asking about new areas
  • Audit scope doesn't match reality

Solutions:

  • Annual scope review
  • Integrate new systems promptly
  • Communicate scope changes to auditor
  • Plan for scope expansion budget

Streamlining Year 2+

Automation Opportunities

Manual Task Automation Solution
Access reviews Automated review workflows
Evidence collection API integrations
Training tracking LMS integration
Policy distribution Automated acknowledgments
Vulnerability tracking Automated scanning + ticketing
Compliance reporting Dashboard automation

Process Improvements

Reduce Overhead

  • Consolidate tools where possible
  • Eliminate redundant controls
  • Streamline approval workflows
  • Use exception-based monitoring

Increase Efficiency

  • Template recurring activities
  • Create runbooks for common tasks
  • Cross-train team members
  • Document tribal knowledge

Building a Compliance Culture

Make Security Normal

  • Include security in onboarding
  • Regular security communications
  • Celebrate security wins
  • Lead by example

Distribute Responsibility

  • Clear control ownership
  • Accountability metrics
  • Regular check-ins with owners
  • Recognition for compliance

Handling Changes During the Year

System Changes

When you add or modify systems:

  1. Assess: Is it in SOC 2 scope?
  2. Document: Update system description
  3. Implement: Apply appropriate controls
  4. Evidence: Start collecting evidence
  5. Notify: Inform auditor if significant

Organizational Changes

When your organization changes:

  1. Access: Update access immediately
  2. Policies: Review for needed updates
  3. Ownership: Reassign control ownership
  4. Training: Ensure new roles are trained
  5. Documentation: Update org charts, contacts

Control Failures

When a control fails:

  1. Detect: Identify the failure quickly
  2. Document: Record what happened
  3. Remediate: Fix the issue
  4. Analyze: Determine root cause
  5. Improve: Prevent recurrence
  6. Report: Note in audit if during period

Audit Preparation Checklist (Year 2+)

3 Months Before Audit

  • Confirm audit dates with auditor
  • Review previous year findings
  • Verify remediation completion
  • Update scope if needed
  • Review policy currency

2 Months Before Audit

  • Conduct internal assessment
  • Identify and address gaps
  • Prepare population lists
  • Review evidence completeness
  • Update system description

1 Month Before Audit

  • Finalize all evidence
  • Complete outstanding access reviews
  • Ensure training is current
  • Stage evidence for auditor
  • Brief control owners

1 Week Before Audit

  • Final evidence check
  • Confirm auditor logistics
  • Brief key personnel
  • Clear calendars for audit support
  • Prepare for kickoff meeting

Measuring Compliance Health

Key Metrics to Track

Metric Target Frequency
Control effectiveness rate > 95% Quarterly
Access review completion 100% Quarterly
Training completion 100% Quarterly
Vulnerability remediation SLA > 90% Monthly
Open audit findings 0 critical Monthly
Policy acknowledgment rate 100% Annual

Compliance Dashboard

Track these indicators:

Overall Health: 94%
Access Reviews: Complete
Training: 98%

Open Findings: 2 items
Evidence Status: Current
Policy Status: Current

Vuln SLA Met: 96%
Vendor Reviews: On Track
Days to Audit: 45

The Bastion Advantage for Ongoing Compliance

Continuous Monitoring

  • Real-time control monitoring
  • Automated gap detection
  • Drift alerts
  • Compliance scoring

Automated Evidence

  • Year-round evidence collection
  • Evidence freshness tracking
  • Audit-ready at any time
  • No last-minute scramble

Expert Support

  • Dedicated vCISO throughout the year
  • Not just at audit time
  • Proactive guidance
  • Change management support

Efficient Renewals

  • Streamlined year 2+ process
  • Historical evidence preservation
  • Auditor relationship management
  • Continuous improvement guidance

Need help maintaining your SOC 2 compliance? Talk to our team →

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