SOC 2 (2017 TSC)·Criterion P6.1·high·Component: Privacy

What this control requires

The entity discloses personal information to third parties with the explicit consent of data subjects and such consent is obtained prior to disclosure to meet the entity's objectives related to privacy.
— SOC 2 (2017 TSC), Criterion P6.1

In plain English

The entity discloses personal information to third parties with the explicit consent of data subjects and such consent is obtained prior to disclosure to meet the entity's objectives related to privacy. In practice, this means you can prove you information objectives-level controls on a defined cadence.

Why it matters

Every SOC 2 audit opinion is built control-by-control from the Trust Services Criteria. A missing or failing criterion produces an exception in the report, which buyers, partners and procurement teams read line-by-line during vendor reviews.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A SOC 2 auditor (under AT-C §§ 105/205) tests both design and operating effectiveness over the audit window. For each criterion they expect a written control, a control owner, a population of events, and a sample tested against the population — including remediation tickets for exceptions.

Within Privacy, the assessor will trace your implementation back to the catalogue reference (Criterion P6.1) and look for objective evidence on the latest two assessment cycles.

How to implement

  1. Write a short policy stating intent, scope and named owner.
  2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
  3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
  4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

  • Information. Document the trigger, the owner and the cadence.
  • Risk. Document the trigger, the owner and the cadence.
  • Security. Document the trigger, the owner and the cadence.
  • Vendor. Document the trigger, the owner and the cadence.
  • Management. Document the trigger, the owner and the cadence.
  • Scope: objectives, protection, management.

Evidence to collect

  • Vendor Risk Management. vendor_risk_management evidence

Third-party risk management evidence (assessments, contracts, due diligence) shows supplier oversight. Focus: Third-Party Disclosure with Data Subject Consent (Original component: Privacy).

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in SOC 2 (2017 TSC)

References

Topics: data protectionvendor riskvendor managementprivacy managementsupply chain securitythird party monitoring