SOC 2 Compliance Consulting & Trust Services Criteria Implementation
SOC 2 compliance consulting, Trust Services Criteria mapping, and audit-ready evidence libraries for Type I and Type II attestation. We build evidence packages that auditors accept.
Bell Tower engineers security controls aligned to SOC 2 Trust Services Criteria for organizations pursuing Type I or Type II attestation.
What We Deliver
- Trust Services Criteria Mapping: We map your controls to Security, Availability, Processing Integrity, Confidentiality, and Privacy criteria, identifying gaps and building remediation roadmaps
- Common Criteria Implementation: Full implementation of CC1.0-CC9.0 controls with documented evidence of operating effectiveness
- SOC 2 Evidence Library: Organized documentation with control references, evidence types, sources, owners, and refresh cadences that satisfy auditor requirements
- Type I & Type II Readiness: Preparation for initial Type I attestation and continuous monitoring infrastructure for Type II operational audits
- Auditor Handoff Package: Bridge letters and evidence narratives that translate compliance tool outputs into formats auditors accept
SOC 2 Implementation
Bell Tower’s SOC 2 consulting addresses all five Trust Services Criteria categories. We begin with gap assessment against the Common Criteria (CC1.0-CC9.0), which form the foundation for all SOC 2 examinations regardless of which TSC categories you include. Our Trust Services Criteria mapping identifies which controls satisfy multiple criteria—enabling efficient compliance without redundant effort.
For organizations already operating under NIST CSF, ISO 27001, or CIS Controls, we provide crosswalk documentation showing how existing controls satisfy SOC 2 requirements. This unified approach means you don’t rebuild your security program for each framework—we demonstrate how one control set satisfies SOC 2, HIPAA, and FINRA/SEC requirements simultaneously.
Common Criteria (CC) Mapping
CC1.0 — Control Environment
Tone at the top, integrity, ethical values, and board oversight. We document governance structures and oversight mechanisms.
Key deliverables:
- Board meeting minutes with security oversight
- Code of conduct and ethics policy
- Organizational structure and reporting lines
- Management review documentation
CC2.0 — Communication and Information
Internal and external communication of objectives, responsibilities, and control operation. We establish information flows that support control effectiveness.
Key deliverables:
- Internal communication procedures
- External communication policies (customers, vendors, regulators)
- Information system documentation
- Control documentation libraries
CC3.0 — Risk Assessment
Risk identification, analysis, and mitigation. We implement risk assessment processes that identify threats to TSC achievement.
Key deliverables:
- Risk assessment methodology and schedules
- Risk registers with likelihood and impact ratings
- Fraud risk assessments
- Change management risk evaluations
CC4.0 — Monitoring Activities
Ongoing and separate evaluations of internal control. We establish monitoring that detects control failures before auditors do.
Key deliverables:
- Continuous monitoring tool configurations
- Internal audit schedules and reports
- Management review meeting records
- Control deficiency tracking and remediation
CC5.0 — Control Activities
Policies and procedures that mitigate risks to objectives. We implement the specific controls that address identified risks.
Key deliverables:
- Control matrices mapped to risks
- Policy and procedure documentation
- Control operation evidence (logs, configurations, test results)
- Segregation of duties matrices
CC6.0 — Logical and Physical Access Controls
Access restriction, authentication, and authorization. We engineer access controls that limit system and data access to authorized users.
Key deliverables:
- Access control policies and standards
- User access provisioning and deprovisioning procedures
- Privileged access management documentation
- Physical access controls and visitor logs
CC7.0 — System Operations
System monitoring, vulnerability management, and incident detection. We establish operations that maintain system availability and security.
Key deliverables:
- System monitoring configurations and alert rules
- Vulnerability management procedures and scan results
- Change management records
- Capacity planning documentation
CC8.0 — Change Management
System change control, testing, and implementation. We implement change processes that prevent unauthorized modifications.
Key deliverables:
- Change management policy and procedures
- Change request and approval records
- Testing documentation and evidence
- Emergency change procedures
CC9.0 — Risk Mitigation
Vendor management, business continuity, and risk transfer. We address risks from third parties and business disruptions.
Key deliverables:
- Vendor risk assessment procedures
- Business continuity and disaster recovery plans
- Insurance and risk transfer documentation
- Third-party SOC 2 reports and contract reviews
Type I vs Type II Attestation
Type I evaluates control design at a specific point in time. Suitable for initial attestation or when operational history is limited. Timeline: 3-4 months from engagement to report.
Type II evaluates both control design and operating effectiveness over a period (typically 6-12 months). Required for vendor assessments and enterprise sales. Timeline: 9-14 months including observation period.
We recommend Type I as a foundation: implement controls, obtain Type I attestation, then operate controls for 6+ months before Type II. This staged approach provides early credibility while building toward the operational evidence Type II requires.
Regulatory Crosswalks: SOC 2 to Compliance Requirements
SOC 2 alignment accelerates compliance with multiple regulatory frameworks. Our crosswalks demonstrate how SOC 2 controls satisfy specific requirements:
HIPAA Security Rule
| SOC 2 CC | HIPAA Requirement | Evidence Artifact |
|---|---|---|
| CC6.1 | 164.312(a) Access Control | Access control policy, user provisioning logs |
| CC6.7 | 164.312(e) Transmission Security | Encryption configuration, TLS certificates |
| CC7.2 | 164.312(b) Audit Controls | SIEM logs, audit trail exports |
| CC4.1 | 164.308(a)(8) Evaluation | Penetration test reports, vulnerability scans |
| CC9.2 | 164.308(a)(6) Security Incident Procedures | IR plan, incident tickets, AARs |
FINRA/SEC Cybersecurity Requirements
| SOC 2 CC | FINRA/SEC Requirement | Evidence Artifact |
|---|---|---|
| CC3.2 | FINRA Rule 4370 Business Continuity | Risk assessment methodology, BCP test results |
| CC6.1 | SEC Regulation S-P | Data classification policy, encryption at rest |
| CC7.1 | FINRA Notice 21-29 | Threat intelligence integration, alert tuning |
| CC4.1 | SEC Investment Advisers Act Rule 206(4)-7 | DR procedures, failover test documentation |
GDPR Article 32
| SOC 2 CC | GDPR Requirement | Evidence Artifact |
|---|---|---|
| CC6.1 | Art. 32(1)(b) Access Control | MFA configuration, privileged access reviews |
| CC6.7 | Art. 32(1)(a) Encryption | Encryption key management, data masking procedures |
| CC7.2 | Art. 32(1)(d) Security Testing | Penetration test reports, vulnerability scans |
| CC4.1 | Art. 33 Breach Notification | Breach assessment procedures, notification logs |
Audit Evidence Library
Auditors require specific evidence types for each Common Criteria. We build organized libraries with clear ownership and refresh schedules:
| Control Ref | Evidence Type | Source | Owner | Refresh Cadence |
|---|---|---|---|---|
| CC1.1 | Board minutes, ethics attestations | Document management | CEO/CISO | Quarterly |
| CC2.1 | Internal communication records | Email/Slack archives | Compliance Officer | Quarterly |
| CC3.1 | Risk assessment documentation | Risk management platform | Risk Manager | Annual |
| CC4.1 | Monitoring tool configurations | GRC platform | Security Operations | Monthly |
| CC5.1 | Control operation logs | SIEM/Cloud platforms | Control Owners | Monthly |
| CC6.1 | Access review attestations | IAM systems | Data Owners | Quarterly |
| CC7.1 | Vulnerability scan results | Scanning tools | Security Engineer | Monthly |
| CC8.1 | Change request approvals | Change management system | Change Manager | Per change |
| CC9.1 | Vendor risk assessments | Vendor management platform | Procurement/Security | Annual |
From Automation to Auditor
Compliance automation tools (Vanta, Secureframe, Drata) generate continuous monitoring data, but auditors often require bridge letters explaining what tools validate versus manual evidence. We prepare SOC 2 auditor handoff packages that:
- Map tool checks to Common Criteria: “Vanta daily checks validate CC6.1 (logical access) via Okta API queries and AWS IAM analysis”
- Identify gaps requiring manual evidence: “Tool monitors configuration but not CC2.1 (internal communication); we provide documented communication procedures and meeting records”
- Translate outputs to auditor formats: Convert JSON exports to narrative control descriptions with timestamps, sampling methodology, and ownership documentation
- Address exceptions: Document control failures, compensating measures, and remediation timelines—transparency auditors expect
Why Bell Tower for SOC 2
Framework Integration: We implement SOC 2 alongside NIST CSF, ISO 27001, and CIS Controls—ensuring unified compliance rather than siloed efforts. One control set satisfies multiple frameworks.
Audit Experience: We’ve guided organizations through SOC 2 examinations for healthcare (HIPAA), finance (FINRA/SEC), SaaS platforms, and digital media companies.
Evidence Engineering: We know what auditors accept. Our SOC 2 evidence libraries include the specific artifacts that prove control effectiveness, not just policy existence.
Continuous Readiness: We build continuous SOC 2 readiness infrastructure—monitoring, evidence collection, and exception handling—that maintains attestation between audits.
Knowledge Transfer: We solve problems and ensure your team understands Trust Services Criteria requirements—building sustainable compliance, not dependency.
Related Resources
- SOC 2 Evidence Library Template — Organized structure for audit-ready evidence documentation
- NIST Cybersecurity Framework Alignment — Map SOC 2 controls to NIST CSF categories
- ISO 27001 Compliance & Audit Readiness — Align SOC 2 Common Criteria with ISO 27001 Annex A
Frequently Asked Questions
How long does SOC 2 implementation take?
Type I typically requires 3-4 months from initial gap assessment to audit completion. Type II requires 9-14 months including the 6-12 month observation period. Organizations with existing security programs (NIST CSF, ISO 27001) often reduce Type I timelines by 4-6 weeks through control reuse.
What’s the difference between Type I and Type II?
Type I evaluates whether controls are designed appropriately at a specific point in time. Type II evaluates whether controls operate effectively over a period (6-12 months). Type I provides initial credibility; Type II provides operational assurance required by enterprise customers and vendor assessments.
Do we need all five Trust Services Criteria?
No. Security (common criteria) is required. Availability, Processing Integrity, Confidentiality, and Privacy are optional based on your service commitments. Most organizations start with Security + Availability or Security + Confidentiality, expanding criteria as customer requirements evolve.
Can we use existing security frameworks for SOC 2?
Yes. Organizations with NIST CSF, ISO 27001, or CIS Controls implementations can leverage existing controls for SOC 2. Our crosswalks demonstrate how existing controls satisfy Trust Services Criteria—reducing implementation effort and avoiding redundant controls.
What evidence do SOC 2 auditors require?
Evidence varies by criteria but generally includes: configuration exports, access logs, test results, policy documents with version control, training records, incident handling documentation, and management review records. We organize these into auditor-friendly libraries with clear ownership and refresh schedules that demonstrate continuous SOC 2 readiness.