The Importance of PII and Compliance issues
PII (Personally Identifiable Information) can be defined as data that directly identifies an individual.
There are various information security and compliance governance documents that businesses can choose to adopt and abide by depending on the organization’s preference or requirements. Systems and Organizations Controls 2, better known
as SOC 2, happens to be one of the many options. SOC 2 was developed by the American Institute of CPAs (AICPA) for the sole purpose of ensuring there would always be proper management of customer data.
SOC 2 is based on five key principles, each of which have a set of controls, also known as focus points, that organizations can choose to implement in ways they see fit. A big benefit of SOC 2 is the flexibility it offers compared to other compliance programs. With SOC 2 the organization can tailor the security program and implement the controls that make the most sense given the end goals.
Security - Provides assurance that the information is safe and that the network has no unauthorized access.
Availability - Focuses on whether the information and system is available for operational purposes and continued use.
Confidentiality - Ensures information that is sensitive or confidential remains protected.
Processing Integrity - Focuses on the systems being complete, accurate, timely, and valid.
Privacy - Put in place to ensure that all data handling is collected, retained, disclosed, and disposed of according to regulation.
The SOC 2 controls span a wide variety of topics such as human resources, board of directors, finance, product line, security and more. When trying to achieve SOC 2 compliance it is critical to choose controls that most focus on customer data protection to include various access controls, encryption methods, and change management procedures.
A large portion of becoming SOC 2 compliant is the documentation of controls in ways of policies and procedures. The documentation not only allows for members of the organization to periodically review it and ensure processes are being followed as originally written, but also the documentation is beneficial for continuity purposes. It can allow for a more seamless transition when individuals depart the organization.
When it is time to apply for SOC 2 compliance, an auditor will review the set of controls and verify that each control has been successfully met and implemented. For instance, if a policy was created and it explained the organizational process for reviewing elevated privileged system accounts, the auditor will expect there to be proof that it was indeed reviewed and documented.
There are two different types of SOC 2 audit reports that can be accomplished.
Type 1: This type allows the auditor to review compliance on or up to a certain date. Often this includes testing vendor systems and focuses more on understanding if the controls are properly designed.
Type 2: This type allows the auditor to view compliance of an organization over a specified period. Most auditors and organizations agree upon a 12-month duration. The audit does not occur for 12 months, but rather the auditor has the ability to take samples throughout the allotted time frame and verify that compliance was being maintained long term. This audit report allows for a clear understanding of the operating effectiveness and compliance over time.
Although it is technically a compliance program, SOC 2 should be thought of as a sales enabler. Businesses that sell products or have any sort of transaction with other businesses such as a wholesaler, or retailer, will have a challenging time gaining trust and closing deals without the SOC 2 compliance certificate. Potential clients want to be able to know that sensitive information such as financial, personal, or business data will remain protected at all costs. It can be a marketing differentiator and a competitive advantage.
In addition to potentially an increase in business partners and sales transactions, there are also benefits in the implementation of all the controls. The implementation phase can bring all the employees together as everyone learns new processes and procedures specifically related to the security of information and customer data. It puts a sense of control back into the organization and allows for a documented streamlined process.
Lastly, SOC 2 can provide the organization with long-term cost savings. With the addition of security prevention measures and various control implementations, it can provide protection from network breaches, mishandling of data, loss of data integrity, and much more. If negative impacts on customer data or mishandling of data were to occur, it can ruin brand reputation and push away potential customers.
SOC 2 is a flexible compliance program that allows the organization to be in control of the choices being made during the documentation and implementation phases. It provides a strong security mindset and culture that can continue to develop as the organization grows. The various audit types allow for an audit of design versus an audit of operational effectiveness and provides leaders of the organization a sense of confidence knowing that the controls addressed in SOC 2 ensures that sensitive customer information and financial data remains secure.