SOC 2 (2017 TSC) P6.6 — Breach and Incident Notification to Stakeholders

What this control requires

The entity provides notification of breaches and incidents to affected data subjects, regulators, and others to meet the entity's objectives related to privacy.

In plain English

The entity provides notification of breaches and incidents to affected data subjects, regulators, and others to meet the entity's objectives related to privacy. In practice, this means you can prove you change 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 P6.6) 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.

Operational checklist

• 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.
• Data. Document the trigger, the owner and the cadence.
• Scope: objectives, response, management, breaches.

Evidence to collect

• Ticketing Workflow. ticketing_workflow evidence

Workflow metrics (ServiceNow, Jira) show approvals and remediation. Focus: Breach and Incident Notification to Stakeholders (Original component: Privacy).

Common pitfalls

• Runbooks that name a role but no person, or list a paging channel that no longer exists.

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.

• NIST SP 800-53 Rev. 5 IR-4(15) — Public Relations And Reputation Repair
• NIST SP 800-171 Rev. 3 3.6.2 — Incident Monitoring, Reporting, and Response Assistance
• CIS Controls v8 17.8 — Conduct Post-Incident Reviews
• ISO/IEC 27001:2022 A.5.27 — Learning from information security incidents
• BSI C5:2020 OPS-21 — Involvement of Cloud customers in the event of incidents

Related controls in SOC 2 (2017 TSC)

• Criterion P6.3 — Logging and Retention of Unauthorized Disclosure Incidents
• Criterion CC7.3 — Incident Detection
• Criterion CC7.4 — Incident Response
• Criterion CC7.5 — Security Incident Recovery Activities
• Criterion P6.5 — Third-Party Breach Notification Commitments
• Criterion P3.1 — Personal Information Collection Aligned with Privacy Objectives

References

• AICPA / ASEC — SOC 2 (2017 TSC)
• Catalogue identifier: Criterion P6.6

Topics: incident responsechange managementprivacy management