SOC2 Policy Management: What You Need to Know

SOC 2 policy management is the practice of creating, maintaining, and demonstrating control over the organizational policies required for SOC 2 compliance. A SOC 2 audit evaluates how an organization manages data based on five Trust Services Criteria, and well-managed policies are the foundation that auditors use to assess whether controls are designed and operating effectively.

What Is SOC 2?

SOC 2 (System and Organization Controls 2) is an auditing framework developed by the American Institute of Certified Public Accountants (AICPA). It evaluates an organization's controls related to five Trust Services Criteria:

• Security — Protection of information and systems against unauthorized access (required for all SOC 2 reports)
• Availability — The system is available for operation and use as committed
• Processing Integrity — System processing is complete, valid, accurate, and timely
• Confidentiality — Information designated as confidential is protected as committed
• Privacy — Personal information is collected, used, retained, disclosed, and disposed of in conformity with commitments

There are two types of SOC 2 reports. A Type I report evaluates whether your controls are properly designed at a specific point in time. A Type II report evaluates whether those controls operated effectively over a period of time, typically six to twelve months. Type II is significantly more rigorous and is what most enterprise customers require from their vendors.

Why Policies Are Central to SOC 2

SOC 2 auditors evaluate your controls, and policies are where controls are documented. When an auditor asks “How does your organization handle access control?”, the answer begins with your access control policy. When they ask “How do you manage incidents?”, they start with your incident response policy.

But having policies is not enough. Auditors want to see that policies are:

• Formally approved by appropriate authority (not just drafted and forgotten)
• Regularly reviewed on a defined schedule with evidence of each review
• Version-controlled with a clear history of changes and approvals
• Distributed to the people they affect, with proof of acknowledgment
• Supported by procedures that describe how policies are implemented in practice
• Backed by evidence demonstrating that procedures are actually followed

This is the full chain that SOC 2 auditors trace: Control → Policy → Procedure → Evidence. Organizations that can demonstrate this chain cleanly and consistently have smoother audits and fewer findings.

Common SOC 2 Policies You Need

While the exact policies required depend on which Trust Services Criteria you include in your audit scope, most SOC 2 engagements require policies covering:

• Information Security Policy — Defines the organization's approach to protecting information assets
• Access Control Policy — Governs who has access to systems and data, and how access is granted, reviewed, and revoked
• Change Management Policy — Describes how changes to systems, applications, and infrastructure are requested, approved, tested, and deployed
• Incident Response Policy — Outlines how security incidents are detected, reported, investigated, and remediated
• Risk Assessment Policy — Defines how the organization identifies, evaluates, and mitigates risks
• Data Classification Policy — Establishes categories for data sensitivity and the handling requirements for each
• Acceptable Use Policy — Sets expectations for how employees use organizational systems and data
• Vendor Management Policy — Governs how third-party vendors are evaluated, onboarded, monitored, and offboarded
• Business Continuity and Disaster Recovery Policy — Defines how the organization maintains operations during and recovers from disruptions
• Human Resources Security Policy — Covers background checks, onboarding, offboarding, and security training requirements

The SOC 2 Policy Management Challenge

For growth-stage companies pursuing SOC 2 for the first time, the policy management challenge is significant. You need to write a comprehensive set of policies, get them approved, map them to framework controls, distribute them to employees, collect attestation signatures, and then prove that the procedures described in those policies are actually followed, all while maintaining version control and audit trails.

Companies that try to manage this with Google Docs or SharePoint quickly encounter limitations. Folder-based document storage does not enforce approval workflows, does not track control mappings, does not manage attestations, and produces no coverage dashboard showing gaps. When audit time comes, gathering evidence becomes a frantic exercise in searching emails and shared drives.

Control Mapping: Connecting Policies to SOC 2 Criteria

SOC 2 controls are the specific requirements defined by the Trust Services Criteria. Control mapping is the process of linking each control to the policies, procedures, and evidence that address it. This mapping is what auditors use to trace compliance.

Effective control mapping requires flexibility:

• One control may be addressed by multiple policy articles (e.g., access control might be addressed in both your Information Security Policy and your HR Security Policy)
• One policy article may address multiple controls (e.g., your encryption policy might map to controls in both Security and Confidentiality criteria)
• Some controls may not apply to your organization and should be documented as “Not Applicable” with justification

A coverage dashboard that shows mapping progress in real-time is invaluable. Instead of maintaining a spreadsheet that is always slightly out of date, you can see at a glance how many controls are mapped, which have gaps, and where you need to focus your effort.

Evidence Collection for SOC 2

For a Type II audit, having policies and procedures is necessary but not sufficient. Auditors need evidence that your controls operated effectively throughout the audit period. This means collecting artifacts, screenshots, logs, and records that prove compliance on an ongoing basis.

Evidence collection should be structured and systematic:

• Evidence templates define what needs to be collected and how often (monthly, quarterly, annually)
• Assignees receive tasks and upload evidence within defined collection periods
• Reviewers evaluate evidence and approve it, mark it incomplete, or fail it
• Failed evidence triggers action plans for remediation

Linking evidence templates directly to procedures (which link to policy articles, which link to controls) creates the complete traceability chain auditors need.

Preparing for Your First SOC 2 Audit

If you are a startup or growth-stage company preparing for your first SOC 2 audit, here is a practical roadmap:

Phase 1: Define Scope (Weeks 1-2)

Work with your auditor to determine which Trust Services Criteria are in scope. Most companies start with Security only for their first engagement and add additional criteria in subsequent years. Define the systems and processes that are included.

Phase 2: Write and Approve Policies (Weeks 3-8)

Draft the required policies, get them reviewed by stakeholders, and formally approve them with documented sign-off. Use a policy management platform that tracks approvals with timestamps and version numbers from the start.

Phase 3: Map Controls (Weeks 6-8)

Map each SOC 2 control to the policy articles that address it. Identify gaps where controls are not yet addressed and prioritize writing additional policy content or procedures.

Phase 4: Link Procedures and Set Up Evidence Collection (Weeks 8-12)

Ensure each policy has supporting procedures that describe implementation. Set up evidence collection templates linked to key procedures and begin the collection cycle so you have evidence accumulating before the audit window opens.

Phase 5: Distribute and Attest (Ongoing)

Distribute policies and procedures to all affected employees and collect attestation signatures. Set up automated review reminders so policies are reviewed on schedule.

How PolicyCo Supports SOC 2 Policy Management

PolicyCo is designed to address every aspect of SOC 2 policy management. Policy articles maintain granular version control with full change tracking. Framework mapping links articles to SOC 2 controls with flexible many-to-many relationships and a pre-built SOC 2 control library. The Coverage Dashboard shows real-time mapping progress so you always know where gaps exist.

Procedures link to policy articles, and evidence templates link to procedures, creating the full traceability chain: Control → Article → Procedure → Evidence. Attestation tracking captures employee acknowledgment, and automated review reminders ensure policies stay current. SSO is included on all plans, because security infrastructure should not be gated behind enterprise pricing, especially for companies building their compliance program for the first time.