mkurman ----|--------|--------| | Risk | ALE coverage (mitigated / total) | > 80% | | Detection | Mean Time to Detect (MTTD) | < 24 hours | | Response | Mean Time to Respond (MTTR) | < 4 hours | | Compliance | Controls passing audit | > 95% | | Hygiene | Critical patches within SLA | > 99% | | Access | Privileged accounts reviewed quarterly | 100% | | Vendor | Tier 1 vendors assessed annually | 100% | | Training | Phishing simulation click rate | < 5% |
Trust Service Criteria Overview
Security (Common Criteria -- always in scope): CC1-CC2 (control environment, communication), CC3 (risk assessment), CC4-CC5 (monitoring, control activities), CC6 (logical/physical access, encryption), CC7-CC8 (system ops, vulnerability mgmt, incident response, change mgmt), CC9 (vendor management, business continuity).
Optional: Availability (A1), Processing Integrity (PI1), Confidentiality (C1), Privacy (P1-P8).
Essential Policies (10 minimum)
Information Security, Access Control (MFA, least privilege, access reviews), Change Management (code review, rollback), Incident Response (detection through post-mortem), Risk Assessment (annual, with register), Vendor Management, Data Classification, Business Continuity/DR (RTO/RPO, backup testing), Acceptable Use, HR Security (background checks, onboarding/offboarding).
Vendor Security Assessment Tiers
| Tier | Data Access | Assessment Level |
|---|---|---|
| Tier 1 | PII/PHI access | Full assessment annually |
| Tier 2 | Business data | Questionnaire + review |
| Tier 3 | No sensitive data | Self-attestation |
Red Flags to Surface Proactively
- Security budget justified by benchmarks rather than risk analysis
- Certifications pursued before basic hygiene (patching, MFA, backups)
- No documented asset inventory -- cannot protect what you do not know you have
- IR plan exists but never tested; security reports to IT, not executive level
- Security questionnaire backlog > 30 days -- silently losing enterprise deals
- Vendor with sensitive data access has not been assessed
Startup-Specific Guidance
Type I vs Type II: Type I examines control design at a point in time (3-6 months, good for closing the first enterprise deal). Type II examines control operation over 3-12 months (what sophisticated buyers want, plan 12 months total). Start Type I immediately; begin Type II observation once controls are in place.
Right-Sizing by Stage: Seed (5-15): foundational controls, automation-heavy, concise policies, one part-time owner. Series A (15-50): dedicated compliance owner or fractional CISO, formal access reviews. Series B+ (50+): full-time security team, internal audit, GRC platform.
Cost-Effective Tooling: Compliance automation (Vanta, Drata, Secureframe — significantly reduces manual effort), SSO (Google Workspace or Okta), MDM (Kandji or Jamf), monitoring (Datadog, PagerDuty), vulnerability scanning (Dependabot, Snyk, Trivy).
Timeline Templates
- Type I Aggressive (3 months): Month 1 scope/gap/policies, Month 2 implementation, Month 3 readiness + audit.
- Type I Standard (6 months): Months 1-2 scope/policies, 3-4 implementation, 5 evidence, 6 audit.
- Type II (12 months): Months 1-6 complete Type I, 6-12 observation + evidence, Month 12 audit.
Output Confidence Tagging
All findings tagged before reaching decision-makers: Verified (confirmed against evidence), Medium (reported but not independently verified), Assumed (inferred, needs validation).
Related Skills
privacy-policy— SOC 2 Privacy criteria (P1-P8) align directly with privacy policy commitments. Ensure consistency.security-review— Technical security controls from security-review map to SOC 2 Common Criteria (CC6, CC7, CC8). Use findings to inform gap analysis.
Examples
Example 1: Enterprise deal requires SOC 2
User: "A prospect wants SOC 2 before signing a $200K contract. We have nothing."
Good output excerpt:
Business case: This $200K deal justifies a $30-50K compliance investment. At your stage, every enterprise deal blocked by missing SOC 2 has an opportunity cost.
Area Status Key Gaps Access Control Partial MFA not enforced on AWS root, no SSO, no formal reviews Change Management Partial GitHub PRs used but no documented policy Incident Response Missing No documented plan, no on-call rotation Risk Assessment Missing No formal risk assessment conducted Recommended approach: Type I in 3 months, then begin Type II observation. Immediate actions: (1) Sign up for compliance automation. (2) Enforce MFA everywhere. (3) Select an auditor with startup experience. Interim response to prospect: Share security questionnaire response, SOC 2 Type I commitment timeline, and a signed mutual NDA with security addendum.
Example 2: Security posture assessment
User: "We already use Okta for SSO and do code reviews. Where are we relative to SOC 2?"
Good output excerpt:
Gap Analysis Summary: 55% ready
Compliant: CC6.1 Okta SSO with MFA, CC8.1 code reviews via PRs. Partial: CC6.2 no quarterly access reviews documented, CC7.2 IRP never tested, CC6.3 no formal offboarding checklist. Missing: CC3.1 no annual risk assessment, CC2.1 no security training, CC9.2 no vendor management, CC4.1 no control monitoring, all 10 required policies need drafting.
Disclaimer: This skill provides SOC 2 preparation guidance for planning purposes only. It does not constitute legal, audit, or professional compliance advice. SOC 2 reports can only be issued by a licensed CPA firm. Engage a qualified auditor to confirm readiness before scheduling an audit.