The SOC 2 Privacy Principle is one (1) of the five (5) Trust Services Principles (TSP) put forth by the American Institute of Certified Public Accountants (AICPA) within the SOC 2 reporting framework. In today’s growing world of regulatory compliance, much emphasis is now being placed on the “Privacy” principle, for which the AICPA defines as the principle that “…addresses the system’s collection, use, retention, disclosure, and disposal of personal information in conformity with the commitments in the entity’s privacy notice and with criteria set forth in generally accepted privacy principles (GAPP) issued by the AICPA and Canadian Institute of Chartered Accountants…”.
Therefore, meeting the rigors of the AICPA Privacy Principle should generally consist of the following:
1. Management. The entity defines, documents, communicates and assigns accountability for its privacy policies and procedures.
Analysis: A good starting point is having a comprehensive set of privacy policies in place that speak to different types of sensitive and confidential information that needs to be protected. Personally Identifiable Information (PII) is the umbrella framework of privacy as it essentially consists of eighteen (18) unique identifiers that should be disclosed. Additionally, it means that all service organizations should include comprehensive language within all contracts and other legal documents that strive to ensure the safety and security of PII within their environment, and for companies using one’s services. Such documentation that should include PII verbiage are the following: Statements of Work (SoW), Service Level Agreements (SLA), Master Service Agreements (MSA), just to name a select few. Specifically, there should be specific boundaries on the use of PII, along with clauses relating to uses outside of such parameters, along with penalties for breaches.
2. Notice. The entity provides notice about its privacy policies and procedures and identifies the purposes for which personal information is collected, used, retained and disclosed.
- If using a boiler plate, generic policy statement, take time to actually customize the content, making it a true fit for your organization.
- Ensure that appropriate legal personnel have thoroughly reviewed the content for completeness and appropriateness for your organization.
3. Choice and consent. The entity describes the choices available to the individual and obtains implicit or explicit consent with respect to the collection, use and disclosure of personal information.
4. Collection. The entity collects personal information only for the purposes identified in the notice.
5. Use, retention and disposal. The entity limits the use of personal information to the purposes identified in the notice and for which the individual has provided implicit or explicit consent. The entity retains personal information for only as long as necessary to fulfill the stated purposes or as required by law or regulation and thereafter appropriately disposes of such information.
6. Access. The entity provides individuals with access to their personal information for review and update.
7. Disclosure to third parties. The entity discloses personal information to third parties only for the purposes identified in the notice and with the implicit or explicit consent of the individual.
8. Security for privacy. The entity protects personal information against unauthorized access (both physical and logical).
Analysis: This essentially comes down to access rights best practices for ensuring the safety and security of PII. It means only authorized personnel can access PII, with the minimum rights necessary for performing one’s responsibilities. Furthermore, terminated users are to have such rights immediately revoked, along with periodic access rights audit being conducted.
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