ClearPass

SOC 2 Control Library

Every SOC 2 control in plain English. Browse by trust criterion, search by keyword, and understand exactly what your auditor will ask — before they ask it.

The nine control families every SOC 2 audit includes. These are the non-negotiables — security, access, operations, and governance.

CC1.1·policy

Organization demonstrates commitment to integrity and ethical values

Management sets the tone at the top — establishing, communicating, and enforcing a culture of ethics and integrity throughout the organization.

How a small company satisfies this

Adopt a written Code of Conduct and Ethics policy. Have every employee sign it at hire and annually. It doesn't need to be long — it needs to exist and be acknowledged.

CC1.2·policy

Board of directors demonstrates independence from management and oversight

The governing body provides oversight of the system, ensuring management doesn't operate without checks. For small companies without a board, this maps to founder/advisor oversight.

How a small company satisfies this

If you have a board, document their oversight of security. If you don't, designate a security owner (usually a founder) and document that responsibility in an org chart or roles document.

CC1.3·policy

Management establishes structure, authority, and responsibility

The organization defines clear roles, responsibilities, and reporting structures so that security accountability is not diffuse or ambiguous.

How a small company satisfies this

Write a simple roles and responsibilities document. Name who owns security, who owns infrastructure, who can approve changes. An org chart plus a one-page RACI is enough for a small team.

CC1.4·process

Organization demonstrates commitment to competence and accountability

The organization hires, trains, and retains competent people and holds them accountable for their security responsibilities.

How a small company satisfies this

Include security responsibilities in job descriptions. Conduct annual performance reviews that touch security adherence. Keep records of security training completion.

CC1.5·process

Management enforces accountability

Management takes corrective action when individuals fail to follow established policies and procedures.

How a small company satisfies this

Document your disciplinary process for policy violations (typically in the employee handbook). You don't need to have used it — you need to have it written down.

CC2.1·process

Organization obtains and uses information to support the system

The organization identifies and captures the information needed to operate the system and meet its objectives — including external information like threat intelligence.

How a small company satisfies this

Subscribe to at least one security advisory feed (US-CERT, vendor security mailing lists). Document that you review advisories relevant to your stack. A simple log of 'reviewed CVEs this month' satisfies this.

CC2.2·policy

Internal communication provides necessary information

Information about security responsibilities, incidents, and changes is communicated internally to the right people at the right time.

How a small company satisfies this

Establish a security communication channel (a #security Slack channel works). Document that security incidents and changes are announced there. Keep an incident log showing you used it.

CC2.3·policy

External communication provides necessary information

The organization communicates security-relevant information to external parties — customers, vendors, regulators — as required.

How a small company satisfies this

Publish a security page or trust center. Create a vulnerability disclosure policy (security.txt). Document your process for notifying customers of breaches (required by law in most states).

CC3.1·policy

Organization identifies and assesses risk

The organization has a defined process for identifying threats, vulnerabilities, and risks to the system and its data.

How a small company satisfies this

Conduct a simple annual risk assessment. List your assets (data, systems), the threats to each (breach, outage, insider), and the likelihood/impact. A spreadsheet with 10-15 rows is sufficient for a small company.

CC3.2·process

Risk assessment considers threats from vendors

The organization considers risks introduced by vendors and business partners who provide services or access to the system.

How a small company satisfies this

Maintain a vendor inventory. For each vendor with data access, note what data they can touch and whether they have their own SOC 2 report. Review the list annually.

CC3.3·process

Risk assessment considers changes that could affect the system

The organization assesses risk when significant changes occur — new products, new vendors, new infrastructure, new regulations.

How a small company satisfies this

Add a 'security review' step to your change process for significant changes. Document that you reviewed risk before launching a new service or onboarding a new vendor.

CC3.4·policy

Risk mitigation decisions are communicated

Management communicates how identified risks are being addressed — accepted, mitigated, or transferred — to the appropriate parties.

How a small company satisfies this

Document your risk treatment decisions in the risk assessment. For each risk, note: accepted, mitigated (how), or transferred (insurance). Review with leadership at least annually.

CC4.1·config

Organization conducts ongoing monitoring of system operations

The organization monitors the system on an ongoing basis to confirm that controls continue to operate effectively.

How a small company satisfies this

Set up automated monitoring — uptime checks, access log reviews, alerting on suspicious activity. Document what you monitor and who reviews the output. A weekly log review checklist satisfies this.

CC4.2·process

Organization evaluates controls to determine if they continue to operate

The organization periodically evaluates whether existing controls still address the risks they were designed to mitigate.

How a small company satisfies this

Conduct an annual control review. Walk through each control and confirm it's still operating as designed. Document the review date and reviewer. This is the backbone of your SOC 2 Type II operating effectiveness evidence.

CC5.1·policy

Organization selects and develops control activities

The organization identifies the specific control activities (policies, procedures, technical controls) needed to address identified risks.

How a small company satisfies this

Map each risk from your risk assessment to a specific control. This is mostly documentation — your policies and procedures are the control activities. The mapping shows the auditor you didn't pick controls at random.

CC5.2·policy

Control activities are deployed through policies and procedures

Selected control activities are formalized in policies and procedures that establish what is expected and how it is accomplished.

How a small company satisfies this

This is the policy library itself. Your access control policy, change management policy, incident response policy, etc. ClearPass drafts these for you — each one is a control activity made formal.

CC5.3·config

Control activities are deployed through technology

The organization uses technology to automate or support control activities — access controls, logging, encryption, monitoring.

How a small company satisfies this

Document the technical controls you rely on: MFA enforcement, SSO, encryption at rest and in transit, logging, alerting. Screenshots of configuration (AWS IAM, GitHub settings, SSO dashboard) serve as evidence.

CC6.1·config

Logical and physical access controls restrict access to the system

The organization restricts logical access to the system and its data to authorized users, and prevents unauthorized access by others.

How a small company satisfies this

Use SSO (Google Workspace, Okta) for all systems. Enforce MFA on every access point. Remove access immediately when someone leaves. Document your onboarding/offboarding access checklist. This is the most-tested control in a SOC 2 audit.

CC6.2·process

Access permissions are provisioned and de-provisioned

The organization has a formal process for granting, changing, and revoking access permissions based on role and need-to-know.

How a small company satisfies this

Document your access request and approval workflow (even if it's a Slack message to IT). Document your offboarding checklist (revoke access within X hours of departure). Keep records of access changes.

CC6.3·process

Access permissions are reviewed

The organization periodically reviews access permissions to confirm they remain appropriate — least privilege.

How a small company satisfies this

Conduct quarterly access reviews. List everyone with admin or sensitive access and confirm they still need it. Document the review with a date and sign-off. This is high-frequency audit evidence for Type II.

CC6.4·config

Unauthorized access is prevented through authentication

The organization uses authentication mechanisms (passwords, MFA, certificates) to verify user identity before granting access.

How a small company satisfies this

Enforce MFA on all systems — not just email. Use SSO to centralize authentication. Document your password policy (length, complexity, rotation if applicable). Screenshots of MFA enforcement settings are key evidence.

CC6.5·config

Access to system components is restricted through network controls

The organization uses network controls (firewalls, segmentation, VPNs) to restrict access to system components.

How a small company satisfies this

Document your network architecture. Use a cloud provider's security groups or firewalls. Restrict database access to application servers only — never to the public internet. A network diagram serves as evidence.

CC6.6·process

Physical access to facilities is restricted

The organization restricts physical access to facilities that house system components (servers, network equipment).

How a small company satisfies this

If you use a cloud provider (AWS, GCP, Azure), their SOC 2 report covers the physical security of the data center — you inherit it. Document that you rely on the provider's report. If you have a physical office, document keycard access and visitor logging.

CC6.7·config

Transmission of data is protected

The organization protects data in transit using encryption (TLS) to prevent unauthorized access or modification during transmission.

How a small company satisfies this

Enforce TLS 1.2+ everywhere. Redirect HTTP to HTTPS. Use HSTS headers. Document that all data in transit is encrypted. A TLS scan (e.g., SSL Labs) screenshot is strong evidence.

CC6.8·config

Data at rest is protected

The organization protects data at rest using encryption to prevent unauthorized access to stored data.

How a small company satisfies this

Enable encryption at rest on all databases, storage volumes, and backups. Most cloud providers make this a checkbox. Document that encryption is enabled and which keys (provider-managed or customer-managed) are used.

CC7.1·config

Organization detects system anomalies and incidents

The organization detects anomalies and security incidents through monitoring, alerting, and logging.

How a small company satisfies this

Centralize logs (CloudTrail, Cloud Logging, a SIEM). Set up alerts for suspicious activity — failed logins, privilege escalation, unusual data access. Document what you alert on and who receives the alerts.

CC7.2·policy

Incidents are responded to

The organization has a defined process for responding to detected incidents — triage, containment, eradication, recovery.

How a small company satisfies this

Write an Incident Response Plan. It doesn't need to be elaborate — define severity levels, who is on the response team, and the steps: detect, contain, eradicate, recover, post-mortem. ClearPass drafts this for you.

CC7.3·policy

Incident response plan includes communication

The incident response process includes procedures for communicating incidents to affected parties — customers, regulators, law enforcement.

How a small company satisfies this

Add a communication section to your IR plan: who notifies customers, within what timeframe (most state laws require 'without unreasonable delay'), and what information is communicated. Reference breach notification laws that apply to you.

CC7.4·process

Incidents are resolved and root cause is identified

The organization resolves incidents, identifies root causes, and implements corrective actions to prevent recurrence.

How a small company satisfies this

Conduct a post-mortem after every significant incident. Document what happened, why, what you fixed, and how you'll prevent it. Keep post-mortem records — they're strong Type II operating effectiveness evidence.

CC7.5·policy

Recovery procedures are in place

The organization has procedures to recover from disruptions — backups, disaster recovery, business continuity.

How a small company satisfies this

Write a simple Disaster Recovery / Business Continuity plan. Document your backup strategy (what, how often, where). Test restoration at least once and document the result. A backup that's never been restored is not a backup.

CC8.1·process

Changes to the system are authorized, tested, and approved

The organization manages changes to the system through a formal change management process — development, testing, approval, deployment.

How a small company satisfies this

Use pull requests with required reviews (GitHub, GitLab). Document your environments (dev, staging, prod). Require approval before deploying to production. Your git history and PR approval records are the evidence — you're probably already doing this.

CC9.1·process

Organization identifies and manages vendor risk

The organization identifies vendors that provide services or access to the system and manages the risk they introduce.

How a small company satisfies this

Maintain a vendor inventory. For each vendor with data or system access, collect their SOC 2 report (or equivalent). Review the inventory annually. Document that you reviewed vendor risk before onboarding a new vendor.

CC9.2·process

Vendor controls are evaluated

The organization evaluates the controls of vendors and business partners to confirm they meet the organization's requirements.

How a small company satisfies this

For each critical vendor, obtain and review their SOC 2 report annually. Document that you reviewed it and noted any qualified opinions or exceptions. Keep the reports on file — the auditor will ask to see them.

Ready to see which of these apply to you?

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