What Documentation Is Required for SOC Audit Readiness

By Oberle Law, PLLC
Women preparing documents for audit

SOC audit readiness requires your business to maintain documentation that demonstrates how your internal controls operate and how your employees follow established procedures. Policies, contracts, training records, and evidence of control activities all contribute to a clear record for an audit. 

At Oberle Law, PLLC, I am dedicated to helping businesses review these materials and identify legal or contractual concerns that could affect their preparation. Located in Bohemia, New York, I serve clients throughout the state. Contact me today to schedule a free consultation and discuss your business's SOC audit documentation needs. 

Gather Essential SOC Audit Documentation

A SOC audit examines whether a business has the appropriate controls and whether those controls operate as described. Because documentation supports this review, your business should begin gathering records well before the audit.

A New York audit preparation lawyer can help you determine which documents relate to your contractual obligations, internal procedures, and business operations. The specific records required will depend on the company's services and the type of SOC examination being conducted. The common types of documentation you should collect include the following:

  • Information security policies: These explain how your business protects its systems, information, and other company resources from unauthorized access.

  • Access control records: These document who has access to your systems, how permissions are granted, and when access is granted or revoked.

  • Employee procedures: Written procedures describe responsibilities for security, onboarding, offboarding, incident reporting, and other relevant activities.

  • Risk assessments: These records identify potential risks and document the steps the business takes to address them.

  • Incident records: Documentation of security incidents and responses can demonstrate how the business handles issues when they occur.

  • Training records: These show when employees received required instruction concerning security policies and business procedures.

  • Vendor documentation: Contracts, evaluations, and other third-party records can establish responsibilities involving data, security, and service delivery.

Collecting these materials gives your business an opportunity to identify missing or outdated records. It also gives legal counsel a foundation for reviewing whether the documentation accurately reflects the company's obligations and practices.

Review Your Policies and Internal Procedures

Your company policies should reflect the way your business actually operates. If your written procedures describe one process while your employees follow another, the discrepancy can create questions during an audit. I can help you review your policies and procedures to identify provisions that don't match your current business practices.

This can involve reviewing your access controls, employee responsibilities, incident response procedures, data handling requirements, and other internal documentation. The important policies you should review include the following:

  • Data protection procedures: These establish requirements for storing, accessing, transmitting, and protecting your business information.

  • Authentication policies: These address your passwords, authentication methods, and account security requirements.

  • Employee access procedures: These establish how system access is provided when your employees begin working and how permissions change when their responsibilities change.

  • Termination procedures: These explain how accounts and system access are removed when an employee leaves your company.

  • Incident response procedures: These establish how your employees report and respond to security incidents.

  • Business continuity procedures: These describe how your business manages disruptions to critical systems and operations.

As an experienced business lawyer, I can review your policies for provisions that create contractual or legal concerns. For example, your company policy shouldn't impose obligations that conflict with an existing agreement or describe procedures it doesn't actually follow. Reviewing these materials before the audit gives you time to make appropriate updates and ensure consistency between written policies and the evidence supporting them.

Document Your Control Activities and Vendor Obligations

Your policies require supporting evidence to show that SOC controls are being followed. Records such as access reviews, approvals, training, monitoring, and testing can demonstrate these activities. I can help review whether your records align with your company procedures and vendor obligations, particularly when third parties handle systems or data.

  • Service agreements: Your contracts should clearly establish responsibilities involving confidentiality, security, and business information.

  • Vendor assessments: Your records should document how your business evaluates third-party risks before and during a relationship.

  • Security documentation: Questionnaires, reports, and related materials can provide evidence of a vendor's security practices.

  • Contract reviews: Periodic reviews can identify changes to obligations, services, or responsibilities that affect audit preparation.

  • Incident provisions: Your agreements should address responsibilities for reporting and responding to security incidents when applicable.

Reviewing these records can help you identify obligations that aren't reflected in your internal policies. It can also help clarify which responsibilities belong to the business and which have been assigned to a service provider.

Address Gaps Before the SOC Audit

After gathering documentation, your business should compare its records with actual processes to identify outdated policies, missing evidence, or unclear responsibilities. My firm can help review your contracts, policies, and records to identify concerns and determine what needs updating. A pre-audit review should consider whether:

  • Documents are current: Your policies should describe your company's existing systems, responsibilities, and procedures.

  • Records are consistent: Evidence of your control activities should correspond with the processes described in your written policies.

  • Responsibilities are clear: Your documentation should identify the individuals or roles responsible for important control activities.

  • Contracts are aligned: Your vendor and customer agreements should be reviewed for provisions affecting security, confidentiality, and reporting duties.

  • Gaps are tracked: Identified documentation deficiencies should be recorded so your business can address them before the audit.

Addressing documentation gaps early gives your business time to make corrections before the SOC audit. My firm can review your policies, contracts, and supporting records to identify concerns and help create a reliable record of the company’s controls.

Get Support From a New York Business Lawyer for Audit Preparation

Preparing SOC documentation takes careful attention to policies, control records, contracts, and third-party obligations. As an experienced business lawyer at Oberle Law, PLLC, I can help you review these materials and address legal concerns connected to your audit preparation.

Reach out to me, Attorney Constance Oberle Geoghan, for assistance with reviewing your SOC audit documentation and discussing the legal considerations affecting your business. Located in Bohemia, New York, I serve clients throughout the state. Call now to schedule a free consultation.