SOC 28 min read

Essential SOC 2 Policies: What You Need and Why

Policies are the foundation of your SOC 2 compliance program. They document your organization's commitment to security and define how controls are implemented. This guide covers every policy you need for SOC 2 and how to create them effectively.

Key Takeaways

Point Summary
Total policies needed 15-20 core policies organized in a 3-tier hierarchy
Tier 1 (must-have) Information Security, Access Control, Acceptable Use, Data Classification, Incident Response, Change Management, Vendor Management
Tier 2 (important) Password, Encryption, Business Continuity, Disaster Recovery, Physical Security
Policy review cycle Annual review with documented version control
Implementation timeline 5-6 weeks from start to leadership approval

Quick Answer: You need 15-20 policies for SOC 2, starting with 7 essential ones: Information Security, Access Control, Acceptable Use, Data Classification, Incident Response, Change Management, and Vendor Management. Plan 5-6 weeks for full implementation.

Why Policies Matter for SOC 2

Auditor Expectations

SOC 2 auditors evaluate your controls against documented policies. Without policies:

  • Controls lack documented requirements
  • There's no standard to measure against
  • Auditors can't verify compliance
  • Your report will have findings

Business Benefits

Well-crafted policies also:

  • Guide employee behavior
  • Establish accountability
  • Support training programs
  • Reduce security incidents
  • Demonstrate organizational commitment

Essential SOC 2 Policies

Tier 1: Must-Have Policies

These policies are required for any SOC 2 audit:

1. Information Security Policy

Purpose: Establishes the overall security governance framework

Key contents:

  • Security objectives and principles
  • Roles and responsibilities
  • Policy hierarchy and structure
  • Compliance requirements
  • Policy review and update process

Sample sections:

1. Purpose and Scope
2. Information Security Objectives
3. Organizational Security Structure
4. Security Principles
5. Policy Framework
6. Roles and Responsibilities
7. Compliance and Enforcement
8. Policy Review

2. Access Control Policy

Purpose: Defines how access to systems and data is managed

Key contents:

  • Access provisioning process
  • Role-based access control
  • Authentication requirements
  • Privileged access management
  • Access review requirements
  • Access termination process

Critical elements:

  • Least privilege principle
  • Multi-factor authentication requirements
  • Password requirements
  • Access review frequency (quarterly recommended)

3. Acceptable Use Policy

Purpose: Defines acceptable and prohibited use of company resources

Key contents:

  • Scope of covered resources
  • Permitted uses
  • Prohibited activities
  • Personal use guidelines
  • Monitoring disclosure
  • Consequences of violations

Common prohibitions:

  • Installing unauthorized software
  • Sharing credentials
  • Accessing inappropriate content
  • Using company resources for personal business
  • Circumventing security controls

4. Data Classification Policy

Purpose: Defines how data is categorized and handled based on sensitivity

Key contents:

  • Classification levels (e.g., Public, Internal, Confidential, Restricted)
  • Classification criteria
  • Handling requirements per level
  • Labeling requirements
  • Reclassification process

Typical classification levels:

Level Description Examples
Public Can be shared externally Marketing materials, press releases
Internal For internal use only Internal procedures, org charts
Confidential Business-sensitive Financial data, strategies
Restricted Highly sensitive Customer PII, credentials

5. Incident Response Policy

Purpose: Defines how security incidents are detected, reported, and handled

Key contents:

  • Incident definition and classification
  • Reporting procedures
  • Response team and responsibilities
  • Incident handling phases
  • Communication protocols
  • Post-incident review process

Incident response phases:

  1. Preparation
  2. Detection and Analysis
  3. Containment
  4. Eradication
  5. Recovery
  6. Post-Incident Review

6. Change Management Policy

Purpose: Defines how changes to systems are requested, approved, and implemented

Key contents:

  • Change types and classifications
  • Change request process
  • Approval requirements
  • Testing requirements
  • Deployment procedures
  • Emergency change process
  • Rollback procedures

Change classifications:

Type Description Approval
Standard Pre-approved, low-risk Auto-approved
Normal Routine changes Manager approval
Major Significant impact CAB approval
Emergency Critical, time-sensitive Post-implementation review

7. Vendor Management Policy

Purpose: Defines how third-party vendors are assessed and managed

Key contents:

  • Vendor classification criteria
  • Risk assessment requirements
  • Security requirements for vendors
  • Contract requirements
  • Ongoing monitoring
  • Vendor termination process

Vendor assessment considerations:

  • Data access level
  • Service criticality
  • Security certifications
  • Incident response capability
  • Subprocessor management

Tier 2: Important Supporting Policies

These policies support core controls and are typically required:

8. Password Policy

Purpose: Defines password requirements and management

Key contents:

  • Password complexity requirements
  • Password length minimums
  • Password expiration (if applicable)
  • Password history requirements
  • Password storage requirements
  • Account lockout rules

Modern recommendations:

  • Minimum 12 characters
  • No mandatory rotation (per NIST)
  • MFA required (reduces password importance)
  • Password manager encouraged

9. Encryption Policy

Purpose: Defines encryption requirements for data protection

Key contents:

  • Encryption at rest requirements
  • Encryption in transit requirements
  • Key management procedures
  • Approved algorithms and key lengths
  • Certificate management

Minimum standards:

  • TLS 1.2+ for data in transit
  • AES-256 for data at rest
  • RSA 2048-bit or higher for asymmetric

10. Business Continuity Policy

Purpose: Defines how operations continue during disruptions

Key contents:

  • Business continuity objectives
  • Critical system identification
  • Recovery time objectives (RTO)
  • Recovery point objectives (RPO)
  • Testing requirements
  • Plan maintenance

11. Disaster Recovery Policy

Purpose: Defines how systems and data are recovered after disasters

Key contents:

  • DR strategy and approach
  • Backup requirements
  • Recovery procedures
  • DR site/environment
  • Testing frequency
  • Communication procedures

12. Physical Security Policy

Purpose: Defines physical access controls and facility security

Key contents:

  • Facility access controls
  • Visitor management
  • Equipment security
  • Environmental controls
  • Media handling
  • Clean desk policy

Note: For cloud-native companies, this may largely reference cloud provider controls.

Tier 3: Additional Policies (As Needed)

13. Remote Work Policy

Purpose: Defines security requirements for remote workers

Key contents:

  • Approved remote work arrangements
  • Device requirements
  • Network security requirements
  • Physical security requirements
  • Data handling in remote settings

14. Mobile Device Policy

Purpose: Defines requirements for mobile device use

Key contents:

  • BYOD vs. company-owned policies
  • MDM requirements
  • Security configuration requirements
  • Lost/stolen device procedures
  • App installation restrictions

15. Data Retention Policy

Purpose: Defines how long data is kept and when it's destroyed

Key contents:

  • Retention periods by data type
  • Legal and regulatory requirements
  • Retention exceptions
  • Destruction methods
  • Documentation requirements

16. Privacy Policy (Internal)

Purpose: Defines how personal information is handled

Key contents:

  • Personal data identification
  • Collection limitations
  • Use restrictions
  • Subject rights procedures
  • Third-party sharing rules

Note: Different from customer-facing privacy notice

Creating Effective Policies

Policy Structure Template

# [Policy Name]

## 1. Purpose
Why this policy exists

## 2. Scope
Who and what the policy covers

## 3. Policy Statements
The actual requirements

## 4. Roles and Responsibilities
Who is responsible for what

## 5. Definitions
Key terms defined

## 6. Related Documents
Links to related policies/procedures

## 7. Compliance
How compliance is measured and enforced

## 8. Exceptions
How exceptions are requested and approved

## 9. Document Control
- Version: X.X
- Effective Date: YYYY-MM-DD
- Next Review: YYYY-MM-DD
- Owner: [Name/Role]
- Approver: [Name/Role]

Policy Best Practices

Be Specific but Flexible

Too vague:

"Passwords must be strong."

Too rigid:

"Passwords must be exactly 14 characters with 2 uppercase, 2 lowercase, 2 numbers, and 2 symbols."

Just right:

"Passwords must be a minimum of 12 characters. Longer passphrases are encouraged. MFA is required for all systems."

Make Policies Achievable

Don't write policies you can't enforce:

  • If you require 24/7 monitoring, ensure you have it
  • If you require quarterly access reviews, schedule them
  • If you require annual training, track completion

Use Clear Language

  • Avoid jargon where possible
  • Define technical terms
  • Use "must" for requirements, "should" for recommendations
  • Write for your actual audience

Keep Policies Current

  • Review policies at least annually
  • Update when processes change
  • Document all revisions
  • Communicate changes to employees

Policy Governance

Policy Hierarchy

Level 1: Information Security Policy (Executive-approved)
    │
Level 2: Domain Policies (Management-approved)
    │       - Access Control Policy
    │       - Incident Response Policy
    │       - etc.
    │
Level 3: Standards (Technical specifications)
    │       - Encryption Standard
    │       - Hardening Standard
    │       - etc.
    │
Level 4: Procedures (Step-by-step instructions)
            - User Provisioning Procedure
            - Backup Procedure
            - etc.

Policy Review Cycle

Policy Tier Review Frequency Approver
Information Security Policy Annual Executive/Board
Domain Policies Annual Security/Management
Standards Annual or as needed Security Team
Procedures As needed Policy Owner

Policy Exceptions

Sometimes exceptions are necessary. Manage them properly:

  1. Request: Formal exception request documenting reason
  2. Risk Assessment: Evaluate security impact
  3. Approval: Appropriate authority approves (or denies)
  4. Documentation: Record the exception and conditions
  5. Expiration: Set expiration date for reassessment
  6. Compensating Controls: Implement mitigations where possible

Common Policy Mistakes

Mistake 1: Copy-Paste Without Customization

Problem: Policies don't match actual practices

Solution: Use templates as starting points, customize to your environment

Mistake 2: Overly Complex Policies

Problem: No one reads or follows them

Solution: Keep policies concise and practical

Mistake 3: Set and Forget

Problem: Policies become outdated

Solution: Schedule annual reviews, update when things change

Mistake 4: No Enforcement

Problem: Policies are ignored without consequences

Solution: Define enforcement, train employees, apply consistently

Mistake 5: Missing Policies

Problem: Auditor identifies gaps

Solution: Use SOC 2 checklist to ensure coverage

Policy Implementation Timeline

Week 1-2: Foundation

  • Information Security Policy
  • Acceptable Use Policy
  • Data Classification Policy

Week 2-3: Access & Operations

  • Access Control Policy
  • Password Policy
  • Change Management Policy

Week 3-4: Response & Continuity

  • Incident Response Policy
  • Business Continuity Policy
  • Disaster Recovery Policy

Week 4-5: Vendors & Specialized

  • Vendor Management Policy
  • Encryption Policy
  • Additional policies as needed

Week 5-6: Review & Approval

  • Leadership review
  • Final approvals
  • Employee communication

The Bastion Approach

Pre-Built Policy Templates

Bastion provides:

  • Complete policy library covering all SOC 2 requirements
  • Templates customized to your industry
  • Version control and approval workflows
  • Automatic update notifications

Expert Customization

Your dedicated vCISO:

  • Reviews policies for your specific context
  • Ensures policies match actual practices
  • Identifies gaps and recommends additions
  • Supports policy approval process

Ongoing Policy Management

  • Annual review reminders
  • Policy update tracking
  • Employee acknowledgment tracking
  • Audit-ready documentation

Need help creating your SOC 2 policies? Talk to our team →

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