SOC 2 (2017 TSC)·Criterion P6.3·high·Component: Privacy

What this control requires

The entity creates and retains a complete, accurate, and timely record of detected or reported unauthorized disclosures (including breaches) of personal information to meet the entity's objectives related to privacy.
— SOC 2 (2017 TSC), Criterion P6.3

In plain English

The entity creates and retains a complete, accurate, and timely record of detected or reported unauthorized disclosures (including breaches) 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.

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 P6.3) and look for objective evidence on the latest two assessment cycles.

How to implement

Incident Response

Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.

Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.

Logging Monitoring

AWS. Org-trail CloudTrail to a central log archive account, GuardDuty in every region, and Security Hub for cross-source correlation.

Azure. Pipe every diagnostic setting into a central Log Analytics workspace; onboard Microsoft Sentinel for SIEM/SOAR.

GCP. Aggregate audit logs in a dedicated logging project with sink to BigQuery; enable Security Command Center Premium and route findings to Chronicle SIEM.

Operational checklist

  • Information. Document the trigger, the owner and the cadence.
  • Change. Document the trigger, the owner and the cadence.
  • Incident. 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.
  • Scope: objectives, protection, response, management, breaches.

Evidence to collect

  • Ticketing Workflow. ticketing_workflow evidence

Workflow metrics (ServiceNow, Jira) show approvals and remediation. Focus: Logging and Retention of Unauthorized Disclosure Incidents (Original component: Privacy).

Common pitfalls

  • Runbooks that name a role but no person, or list a paging channel that no longer exists.
  • Per-account logging that nobody stitches together at the org level — incidents that cross accounts go undetected for days.

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 protectionincident responsechange managementprivacy managementlogging monitoring