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04 Trust Services Criteria

The Trust Services Criteria (TSC) form the foundation of SOC 2 reporting.

They provide the criteria service organizations use to design, operate, and demonstrate controls related to:

Security
Availability
Processing Integrity
Confidentiality
Privacy

The most important point to understand is:

SOC 2 is not built around a fixed list of mandatory controls. It is built around criteria that organizations satisfy through controls appropriate to their own systems, risks, commitments, and operations.

This means two companies can both have successful SOC 2 examinations while implementing different controls.

For GRC professionals, the Trust Services Criteria provide the bridge between:

Business Risk
SOC 2 Criteria
Enterprise Control
Evidence
Auditor Testing
SOC 2 Assurance

By the end of this lesson, you will be able to:

  • Explain the purpose of the Trust Services Criteria.

  • Understand the five Trust Services Categories.

  • Explain the role of the Common Criteria.

  • Understand Control Environment criteria.

  • Understand Communication and Information criteria.

  • Understand Risk Assessment criteria.

  • Understand Monitoring Activities criteria.

  • Understand Logical and Physical Access criteria.

  • Understand System Operations criteria.

  • Understand Change Management criteria.

  • Understand Risk Mitigation criteria.

  • Understand Availability criteria.

  • Understand Processing Integrity criteria.

  • Understand Confidentiality criteria.

  • Understand Privacy criteria.

  • Translate criteria into practical controls.

  • Build TSC-to-control mappings.

  • Identify appropriate control evidence.

  • Design control-testing procedures.

  • Identify TSC coverage gaps.

  • Prepare a SOC 2 readiness control matrix.

The Trust Services Criteria are used to evaluate controls relevant to the security and reliability of systems and information.

The framework can be viewed as:

Trust Services Criteria
Common Criteria
+
Additional Category Criteria
Enterprise Controls
Evidence
SOC 2 Examination

The categories are:

Security
Availability
Processing Integrity
Confidentiality
Privacy

Security is foundational.

The other categories are selected based on the service organization’s commitments and system requirements.

Security addresses protection of information and systems against unauthorized access, unauthorized disclosure, damage, and other threats that could compromise the organization’s objectives.

A simple model:

Threat
Unauthorized Access
System / Data Impact
Security Controls

Availability concerns whether systems and services are available for operation and use as committed or agreed.

It may involve:

Capacity
Resilience
Monitoring
Backup
Recovery
Continuity

Processing Integrity addresses whether processing is:

Complete
Valid
Accurate
Timely
Authorized

for the intended purpose.

Confidentiality addresses protection of information designated as confidential.

Examples include:

Customer Data
Trade Secrets
Source Code
Contracts
Internal Business Information

Privacy addresses personal information throughout its lifecycle.

Example:

Collection
Use
Retention
Disclosure
Access
Deletion

The Security category contains the criteria commonly referred to as the Common Criteria.

These provide the foundation for SOC 2.

They cover broad control areas such as:

Control Environment
Communication & Information
Risk Assessment
Monitoring Activities
Control Activities
Logical & Physical Access
System Operations
Change Management
Risk Mitigation

They are called common because they form the foundation that supports the broader Trust Services framework.

Conceptually:

Security Common Criteria
Foundation
+
Availability
Processing Integrity
Confidentiality
Privacy

This distinction is critical.

A criterion describes an objective or condition that should be achieved.

A control describes what the organization actually does.

Example criterion concept:

Restrict logical access.

Possible control:

Privileged access to production systems requires approved role assignment, MFA, and quarterly access review.

11. One Criterion Can Have Multiple Controls

Section titled “11. One Criterion Can Have Multiple Controls”

Example:

Logical Access Criterion
User Provisioning
MFA
RBAC
Access Review
Termination

Several controls may collectively satisfy the criterion.

12. One Control Can Support Multiple Criteria

Section titled “12. One Control Can Support Multiple Criteria”

Example:

Centralized Logging

may support:

Security
Monitoring
System Operations
Incident Response

This is why control mapping matters.

The Control Environment establishes the governance foundation for security and compliance.

It includes concepts such as:

Leadership
Ethics
Accountability
Authority
Responsibility
Oversight

An organization should clearly define:

Board / Management Oversight
Security Leadership
Control Ownership
Escalation
Accountability

Example:

Management establishes and periodically reviews information-security policies defining organizational security responsibilities and expectations.

Evidence:

Approved Policy
Approval Record
Review History

Roles should be clearly defined.

Example:

CISO
Security Governance
SOC
Monitoring
IAM
Identity Controls
Engineering
Secure Systems

Every key control should have an accountable owner.

Example:

Control Owner
MFA IAM Director
Logging SOC Manager
Change Management Engineering Manager

Organizations should ensure personnel responsible for controls have appropriate skills and knowledge.

Evidence may include:

Job Descriptions
Training Records
Qualifications
Performance Reviews

Control failures should not remain ownerless.

A strong environment answers:

Who owns this control?
Who operates it?
Who reviews it?
Who escalates failure?

The organization should identify and communicate information needed to support controls.

Examples:

Security Policies
Standards
Procedures
Risk Information
Incident Escalation
Customer Commitments

Employees should understand relevant responsibilities.

Examples:

Acceptable Use
Access Rules
Incident Reporting
Data Handling

Organizations may also communicate with:

Customers
Vendors
Regulators
Auditors
Business Partners

Security policies and relevant changes are communicated to employees through approved internal channels and training processes.

Evidence:

Policy Publication
Training Record
Acknowledgment

Risk assessment is central to SOC 2.

The organization should understand risks that could prevent achievement of its commitments and system objectives.

A practical process:

Asset / Service
Threat
Vulnerability
Likelihood
Impact
Risk
Control

Risks may include:

Cyberattack
Credential Compromise
Service Failure
Vendor Failure
Data Leakage
Processing Error
Privacy Violation

Organizations should also consider fraud-related risks where relevant.

Examples:

Unauthorized Transactions
Privilege Abuse
Data Manipulation
Management Override

Major organizational or technology changes can introduce new risk.

Examples:

New Cloud Provider
Acquisition
AI Feature
New Data Region
Architecture Migration

These should trigger reassessment.

The organization performs formal security risk assessments at least annually and following significant changes to systems, services, or business operations.

Evidence:

Risk Register
Assessment Report
Risk Treatment Plan

Organizations should monitor whether controls continue to operate effectively.

Monitoring may include:

Control Testing
Management Reviews
Metrics
Audits
Automated Monitoring

Example:

MFA Coverage
Daily Measurement
Logging Coverage
Continuous Monitoring

In addition to ongoing monitoring:

Internal Audit
Control Assessments
SOC Readiness Reviews

can provide independent evaluation.

Control failures should be communicated to responsible management.

Example:

Control Failure
Finding
Owner
Remediation
Retest

Control owners periodically review control-performance metrics and remediate identified deficiencies according to documented timelines.

Access criteria address protection of systems and information from unauthorized access.

Major control areas include:

Identity Lifecycle
Authentication
Authorization
Privileged Access
Physical Security
Access Removal

A standard process:

Access Request
Approval
Account Creation
Role Assignment

Users should receive only the access needed.

Weak:

Developer
→ Global Administrator

Strong:

Developer
→ Required Development Role

Strong authentication is especially relevant for:

Administrators
Remote Access
Sensitive Systems
Critical SaaS

A mature privileged-access lifecycle:

Request
Approval
Temporary Access
Logging
Review
Removal

Example:

Privileged user access is reviewed quarterly by authorized management.

Evidence:

User Population
Reviewer
Review Decisions
Removed Access

Access should be removed when no longer required.

Example:

HR Termination
Identity Platform
Access Removed

Where the organization operates physical facilities, controls may include:

Badge Access
Visitor Management
CCTV
Restricted Areas

For cloud-hosted systems, some physical controls may be inherited from providers.

Production administrative access requires an individually assigned identity, MFA, approved role assignment, and centralized logging.

System Operations criteria address the secure and reliable operation of systems.

Areas may include:

Monitoring
Vulnerability Management
Incident Detection
Incident Response
Backup
System Maintenance

Organizations should monitor relevant security events.

Examples:

Suspicious Authentication
Administrative Changes
Malware
Configuration Changes

A lifecycle:

Discover
Assess
Prioritize
Remediate
Validate

Example:

Security Event
SIEM
Detection Rule
Alert
Investigation

A typical lifecycle:

Prepare
Detect
Analyze
Contain
Recover
Learn

Security incidents are documented, classified, investigated, escalated, and resolved according to the approved incident-response procedure.

Relevant controls may cover:

Backup
Retention
Failure Monitoring
Restore Testing

Examples:

Monitoring Alerts
Incident Tickets
Vulnerability Reports
Backup Reports
Recovery Tests

Change Management criteria address controlled modification of systems and infrastructure.

A standard process:

Change Request
Risk Review
Testing
Approval
Deployment
Validation

Changes should be approved before implementation where required.

Evidence:

Change Ticket
Approver
Deployment Record

Changes should be tested before production deployment.

Examples:

Functional Testing
Security Testing
Regression Testing

Where practical:

Developer
Cannot Independently
Approve + Deploy

Emergency changes should still be controlled.

Example:

Emergency Change
Immediate Implementation
Post-Implementation Review

Modern change-management evidence may include:

Pull Request
Peer Review
CI/CD Logs
Policy-as-Code Results
Deployment Records

Production changes must be documented, tested, approved, and deployed through authorized change-management processes.

Risk Mitigation criteria address how organizations identify and respond to risks arising from business relationships and changes.

This includes areas such as:

Third Parties
Vendors
Subprocessors
Business Changes
Technology Changes

A typical lifecycle:

Vendor Request
Risk Assessment
Security Review
Approval
Monitoring
Offboarding

Evidence may include:

SOC 2 Report
ISO Certificate
Security Questionnaire
Risk Assessment
Contract

Critical providers should be reassessed periodically.

Triggers may include:

Major Incident
SOC Report Expiry
Material Service Change
Subprocessor Change

Critical third-party service providers undergo risk-based due diligence before onboarding and periodic reassessment throughout the relationship.

If Availability is included, organizations should establish controls supporting commitments regarding system availability.

Key areas include:

Capacity
Resilience
Backup
Recovery
Monitoring

Organizations should understand whether resources can support demand.

Example:

Usage
Threshold
Alert
Capacity Expansion

Evidence:

Uptime Dashboard
Availability Alerts
Incident Records

Controls may include:

Redundancy
Multiple Availability Zones
Failover
Load Balancing

Backup controls support recovery but do not alone prove availability.

Remember:

Backup Exists
Recovery Works

A recovery test should validate:

Can data be restored?
Can systems be recovered?
Are RTO/RPO objectives met?

Critical services are monitored continuously, backed up according to approved schedules, and periodically tested for recovery against established objectives.

Processing Integrity addresses whether processing achieves its intended purpose.

Key concepts:

Complete
Accurate
Authorized
Timely
Valid

Examples:

Data Validation
Required Fields
Format Checks
Authorization

Examples:

Automated Rules
Calculation Logic
Duplicate Prevention
Error Handling

Examples:

Output Validation
Reconciliation
Exception Reports
Transactions Submitted:
10,000
Transactions Processed:
9,600

A reconciliation control should identify the difference.

The system validates submitted transactions, identifies processing exceptions, and reconciles input and output totals to ensure complete and accurate processing.

Confidentiality applies when the organization makes commitments to protect information designated as confidential.

Controls may cover:

Classification
Access
Encryption
Sharing
Retention
Deletion

A classification model may include:

Public
Internal
Confidential
Restricted

Use:

Need to Know
Least Privilege
Role-Based Access

Relevant controls may address:

Data at Rest
Data in Transit
Key Management

Confidential information should not be shared without authorization.

Examples:

External Sharing
File Transfer
SaaS Sharing
API Access

Confidential information should not remain indefinitely without business or legal need.

Examples:

File Deletion
Storage Destruction
Cloud Data Deletion

Confidential information is classified, access-restricted, encrypted where required, retained according to policy, and securely disposed when no longer needed.

Privacy addresses personal information.

A privacy lifecycle may include:

Notice
Collection
Use
Retention
Access
Disclosure
Deletion

Organizations should communicate relevant privacy practices.

Personal information should be collected appropriately according to defined purposes.

PII should be used consistently with authorized purposes.

Personal information should be retained according to defined requirements.

Depending on applicable commitments and requirements, organizations may support:

Access
Correction
Deletion

Personal information sharing should be controlled.

Privacy events should be identified and managed.

Examples:

Unauthorized Disclosure
Incorrect Recipient
Excessive Access
Improper Retention

Personal information is collected, used, retained, disclosed, and deleted according to documented privacy commitments and approved processing requirements.

A scalable SOC 2 program uses:

Trust Services Criterion
Enterprise Control
Owner
Evidence
Testing

Criterion area:

Logical Access

Controls:

IAM-001
User Provisioning
IAM-002
Privileged MFA
IAM-003
Quarterly Access Review
IAM-004
Termination

Controls:

CHG-001
Change Authorization
CHG-002
Testing
CHG-003
Production Deployment
CHG-004
Emergency Changes

Controls:

LOG-001
Central Logging
IR-001
Incident Response
VUL-001
Vulnerability Management
BCK-001
Backup

Create:

01 Trust Services Criteria Mapping Matrix

Use:

Criterion Area Risk Enterprise Control Owner Evidence

98. Build Common Criteria Control Register

Section titled “98. Build Common Criteria Control Register”

Create:

02 Common Criteria Control Register

Recommended fields:

Control ID
Criterion Area
Control Statement
Owner
Frequency
Evidence
Status

Create:

03 Risk-to-TSC Mapping

Use:

Risk TSC Area Control Residual Risk

Example:

| Privileged Credential Compromise | Logical Access | IAM-002 | Low |

Create:

04 SOC 2 Evidence Matrix

Use:

Control Evidence Source Frequency Owner
User Inventory
Access Request
MFA Report
Access Review
Termination Ticket

102. Evidence Example — Change Management

Section titled “102. Evidence Example — Change Management”
Change Ticket
Pull Request
Approval
Test Results
Deployment Log

103. Evidence Example — Incident Response

Section titled “103. Evidence Example — Incident Response”
Incident Register
Investigation Ticket
Timeline
Post-Incident Review
Vendor Inventory
Risk Assessment
SOC Report
Approval
Reassessment
Availability Report
Backup Report
DR Test
Incident Record

Create:

05 SOC 2 Control Testing Checklist

For each control document:

Population
Sample
Evidence
Test Procedure
Exceptions
Conclusion

Ask:

If this control operates exactly as designed, will it reasonably satisfy the criterion and address the risk?

Example:

Risk:

Privileged Access Abuse

Control:

Administrator list reviewed once every five years.

The control may exist but be poorly designed.

Ask:

Did the control operate as designed throughout the assessment period?

Example:

Quarterly Review
Q1 ✓
Q2 ✓
Q3 ✗
Q4 ✓

Conclusion:

Partially Effective

For each control identify the full population.

Example:

Access Requests:
1,250

or:

Quarterly Reviews:
4

For manual controls, auditors may sample.

Examples:

Access Requests
Changes
Incidents
Vendor Reviews

Automation may enable testing:

100% MFA Coverage
100% Encryption Coverage
100% Logging Coverage

For every test exception ask:

Requirement?
Condition?
Cause?
Risk?
Frequency?
Systemic?

Control:

Terminated users are disabled within 24 hours.

Population:

75 Terminations

Sample:

25

Exceptions:

3

Potential finding:

Three of twenty-five sampled terminated-user accounts remained active beyond the required removal period.

Possible root cause:

HR termination feed
does not include contractors.

Corrective action should address the process, not just disable three accounts.

Create:

Category Applicable Controls Status
Security Yes 40 Effective
Availability Yes 8 Effective
Processing Integrity No N/A
Confidentiality Yes 7 Partial
Privacy No N/A

Do not include optional categories merely because they sound good.

They should reflect:

Service Commitments
System Requirements
Customer Expectations
Risk

Example:

Availability Included

but:

No Recovery Testing Control

Result:

Control Coverage Gap

Example:

Quarterly Access Review Control Exists

but:

Q2 Evidence Missing

Result:

Evidence / Operating Effectiveness Gap

Example:

Vulnerability Scan
→ Annual

but the risk requires significantly more frequent assessment.

Result:

Design Gap

A practical readiness process is:

Define Scope
Select TSC Categories
Map Criteria
Inventory Controls
Identify Owners
Map Evidence
Perform Gap Assessment
Remediate
Operate Controls
Readiness Review
SOC 2 Examination
  • Security policies established.

  • Roles defined.

  • Management oversight established.

  • Control owners assigned.

  • Employee responsibilities communicated.

  • Risk assessment performed.

  • Fraud risk considered.

  • Major changes assessed.

  • Risk treatment documented.

  • Control monitoring established.

  • Findings documented.

  • Deficiencies escalated.

  • Corrective actions tracked.

  • User provisioning controlled.

  • MFA implemented.

  • Privileged access controlled.

  • Access reviews performed.

  • Termination process established.

  • Physical access controlled where applicable.

  • Security monitoring implemented.

  • Vulnerability management established.

  • Incident response established.

  • Backup monitored.

  • Operational issues tracked.

  • Changes documented.

  • Testing performed.

  • Approval required.

  • Production deployment controlled.

  • Emergency changes reviewed.

  • Vendor inventory maintained.

  • Vendor risk assessed.

  • Critical providers monitored.

  • Provider assurance reviewed.

Mistake 1 — Copying Controls From Another Company

Section titled “Mistake 1 — Copying Controls From Another Company”

Controls should reflect your own system.

Mistake 2 — Treating Criteria as a Checklist

Section titled “Mistake 2 — Treating Criteria as a Checklist”

The objective is effective control, not wording duplication.

Mistake 3 — No Risk-to-Control Connection

Section titled “Mistake 3 — No Risk-to-Control Connection”

Controls become compliance theater.

Control environments become difficult to operate and evidence.

Example:

Security is monitored.

Not testable.

Evidence collection becomes difficult.

Mistake 7 — Evidence Defined Only at Audit Time

Section titled “Mistake 7 — Evidence Defined Only at Audit Time”

Audit preparation becomes chaotic.

Mistake 8 — Optional Categories Selected Without Need

Section titled “Mistake 8 — Optional Categories Selected Without Need”

SOC 2 scope becomes unnecessarily complex.

Mistake 9 — Automated Controls Not Governed

Section titled “Mistake 9 — Automated Controls Not Governed”

Automation itself may fail.

Mistake 10 — Failed Controls Do Not Update Risk

Section titled “Mistake 10 — Failed Controls Do Not Update Risk”

SOC 2 becomes disconnected from enterprise risk.

TSC Requirement
Copy Generic Control
Collect Screenshot
System Commitment
Risk
Applicable Criterion
Enterprise Control
Owner
Evidence
Testing
Remediation

A GRC professional supporting the Trust Services Criteria may:

  • Determine applicable TSC categories.

  • Interpret criteria.

  • Build control mappings.

  • Maintain the SOC 2 control library.

  • Assign and track control ownership.

  • Map risks to criteria.

  • Map evidence to controls.

  • Perform readiness assessments.

  • Identify control-design gaps.

  • Review operating-effectiveness evidence.

  • Coordinate control testing.

  • Track findings.

  • Facilitate remediation.

  • Maintain SOC 2 dashboards.

  • Support external auditors.

GRC connects:

Management
Security
Engineering
IAM
SOC
Privacy
Legal
Vendors
Auditors
Generic controls
Manual evidence
Owners
Processes
Evidence
Risk Mapping
Control Testing
Gap Management
Automated Evidence
Control Metrics
Continuous Monitoring
Dynamic Risk
Continuous Control Status
Automated Evidence
Audit-Ready Assurance

For every criterion ask:

What commitment does this support?
What system is in scope?
What risk does it address?
What control satisfies it?
Who owns the control?
How often does it operate?
What evidence proves it?
Is the evidence reliable?
How will an auditor test it?
What happens if the control fails?
Does the failure affect another TSC category?
How will remediation be validated?

When these questions can be answered, the Trust Services Criteria become an operational control framework rather than an audit checklist.

  • The Trust Services Criteria form the foundation of SOC 2.

  • The five categories are Security, Availability, Processing Integrity, Confidentiality, and Privacy.

  • Security and its Common Criteria provide the core SOC 2 foundation.

  • Criteria describe desired outcomes; controls describe how organizations achieve those outcomes.

  • One criterion may require multiple controls, and one control may support multiple criteria.

  • The Common Criteria address governance, communication, risk assessment, monitoring, access, operations, change management, and risk mitigation.

  • Availability focuses on service availability, capacity, resilience, backup, and recovery.

  • Processing Integrity focuses on complete, valid, accurate, timely, and authorized processing.

  • Confidentiality focuses on information designated as confidential.

  • Privacy governs personal information across its lifecycle.

  • Controls should be specific, owned, repeatable, and testable.

  • Evidence should be defined before audit time.

  • Design effectiveness and operating effectiveness are separate questions.

  • SOC 2 readiness requires criteria mapping, control inventory, evidence mapping, testing, remediation, and sustained operation.

  • GRC plays a central role in translating Trust Services Criteria into practical controls and audit-ready assurance.

Before continuing, make sure you can answer:

  1. What are the Trust Services Criteria?

  2. What are the five Trust Services Categories?

  3. What are the Common Criteria?

  4. What is the difference between a criterion and a control?

  5. Why can one control support multiple criteria?

  6. What does the Control Environment address?

  7. Why is communication important?

  8. How does risk assessment support SOC 2?

  9. What are Monitoring Activities?

  10. What should logical access controls cover?

  11. What does System Operations address?

  12. What is the purpose of Change Management?

  13. How does vendor risk relate to Risk Mitigation?

  14. What does Availability address?

  15. What does Processing Integrity address?

  16. What does Confidentiality address?

  17. How is Privacy different from Confidentiality?

  18. What is design effectiveness?

  19. What is operating effectiveness?

  20. What role does GRC play in applying the Trust Services Criteria?

➡️ Next: 05 — Security Principle

In the next lesson, you will focus specifically on the Security category, which forms the mandatory foundation of every SOC 2 engagement.

You will go deeper into:

Security Governance
Risk Management
Identity & Access Management
Privileged Access
Network Security
Vulnerability Management
Security Monitoring
Incident Response
Change Management
Third-Party Security

You will also build practical SOC 2 artifacts including a Security Control Matrix, IAM Evidence Register, Vulnerability Management Control Map, Security Monitoring Evidence Matrix, Incident Response Control Register, and Security Control Testing Checklist.