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

What this control requires

The entity creates and retains a complete, accurate, and timely record of authorized disclosures of personal information to meet the entity's objectives related to privacy.
— SOC 2 (2017 TSC), Criterion P6.2

In plain English

The entity creates and retains a complete, accurate, and timely record of authorized disclosures of personal information 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.

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 P6.2) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

  • Information. Document the trigger, the owner and the cadence.
  • Management. Document the trigger, the owner and the cadence.
  • Privacy. Document the trigger, the owner and the cadence.
  • Personal. Document the trigger, the owner and the cadence.
  • Data. Document the trigger, the owner and the cadence.
  • Scope: objectives, protection, management.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Recordkeeping of Authorized Personal Information Disclosures (Original component: Privacy).

Common pitfalls

  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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 protectionprivacy managementpolicy management