When undergoing a SOC 2 audit, many organizations aim for a clean report, but even the most prepared companies can encounter exceptions. A SOC 2 exception highlights areas where controls did not fully operate as intended, raising potential concerns for stakeholders. But what exactly does this mean for your business? In this post, we'll break down what a SOC 2 exception is, why it happens, and what steps you can take to address these findings to ensure your organization remains on track for compliance and security.

A SOC 2 exception doesn’t necessarily indicate a failure, but rather an area where controls didn’t function as expected during the audit period, possibly for an entirely legitimate reason. These exceptions can vary in severity, ranging from minor deviations to more significant issues that may require immediate attention. The key is understanding the nature of the exception and determining whether it poses a material risk to your organization’s security, availability, or data privacy. In many cases, exceptions are manageable and can be addressed with corrective actions, helping your organization strengthen its overall control environment.

Types of SOC 2 Exceptions

There are typically two types of SOC 2 exceptions: control deficiencies and deviations.

• Control deficiencies occur when the control was in place but didn’t operate effectively. For example, if an organization has a control for monitoring access logs but failed to review the logs during a certain period, that would be considered a control deficiency.
• Deviations happen when a control did not operate as documented. An example would be a policy stating that users must watch a security awareness training by a certain deadline, but a small number did not watch the video until a week after the deadline, perhaps because they went on vacation shortly before the final reminder was sent.

Understanding the type of exception helps your organization prioritize remediation efforts and prevent similar occurrences in the future.

Why Do SOC 2 Exceptions Happen?

SOC 2 exceptions can occur for several reasons, including human error, system malfunctions, or process misalignment. In some cases, exceptions may result from a temporary breakdown in communication between departments, leading to missed compliance steps. Other times, they stem from inadequate documentation or outdated policies that no longer reflect the current operations or risks the company faces.

It’s essential to perform a root cause analysis when exceptions arise to identify the underlying issues. This allows organizations to apply targeted corrective actions rather than short-term fixes.

The Impact of SOC 2 Exceptions

The impact of a SOC 2 exception depends on its severity and relevance to the scope of the audit. For example, a minor exception might not affect the overall audit opinion and could be seen as a learning opportunity. However, more significant exceptions could lead to a qualified opinion, which might cause concerns for clients, partners, or regulators.

A qualified opinion doesn’t necessarily mean your organization is not secure, but it may indicate weaknesses in certain areas that need attention. Clients and partners might request additional information to understand the risk posed by the exception and what steps are being taken to resolve it.

How to Address SOC 2 Exceptions

If your SOC 2 report identifies exceptions, the most important thing is to respond proactively. Here are steps you can take to manage and resolve exceptions effectively:

1. Understand the exception: Work with your auditor to understand the specific nature of the exception. Is it a process failure, human error, or system issue?
2. Perform a root cause analysis: Identifying the underlying conditions that enabled and/or caused the exception is important in order to identify likely corrections.
3. Implement corrective actions: Develop a plan to remediate the exception. This could involve updating policies, improving employee training, or enhancing technical controls to ensure the issue doesn’t recur.
4. Communicate with stakeholders: Transparency is key when exceptions are identified. Inform relevant internal and external stakeholders about the nature of the exception, your remediation plan, and the expected timeline for resolution.
5. Monitor and document progress: Keep track of the remediation efforts and document each step. This not only helps with the current issue but also serves as a valuable record for future audits.

Preventing SOC 2 Exceptions

While exceptions can happen, there are proactive steps organizations can take to reduce the likelihood of encountering them in future audits:

• Regular internal audits: Conduct internal audits to catch potential issues before the SOC 2 audit. This allows you to address any gaps in controls proactively.
• Ongoing employee training: Ensure your staff is well-versed in the policies and procedures required for SOC 2 compliance. Regular training can help prevent human errors and process deviations.
• Keep policies up to date: As your organization grows or changes, your policies should evolve too. Regularly review and update your procedures to reflect your current operations and risks.

Final Thoughts

SOC 2 exceptions are a common part of the auditing process, but they don’t have to derail your compliance efforts. By understanding the nature of exceptions, implementing corrective actions, and continuously improving your controls, your organization can strengthen its security posture and maintain trust with clients and partners. Embracing these opportunities for improvement will not only help you pass future SOC 2 audits but also ensure you’re better equipped to handle the complex cybersecurity landscape.

About Securisea

Securisea provides audit support for organizations of all sizes, from startups to some of the world’s largest, most complex, and most security-minded technology companies. We are one of only a handful of audit firms in the world certified to provide CSA STAR, ISO27001 and 27701, SOC2, SOC1, PCI DSS, FedRAMP/StateRAMP 3PAO, HITRUST & HIPAA assessments all under one roof. Partnering with Securisea means you have access to experienced, senior security experts focused on delivering the solutions you need.

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Achieving and maintaining PCI Compliance is essential to online retailers that want to prove to customers that their sensitive cardholder data is secure. The most common way to do this is through the PCI Self-Assessment Questionnaire (SAQ) A, but with the introduction of PCI DSS v4.0, new requirements have been added, specifically around Approved Scanning Vendor (ASV) scans. 

What is PCI DSS SAQ A?

Any business that stores, processes, or transmits credit card data must demonstrate PCI compliance. To do so, companies can often complete the "PCI DSS Self-Assessment Questionnaire," but it’s important to check with your acquiring bank to confirm the appropriate SAQ for your situation.

Different types of SAQs are available, depending on how payment processing is handled. Online merchants, for example, often choose between SAQ A-EP and SAQ A. For merchants who outsource payment processing to PCI-certified third parties, SAQ A has been a simpler option because it traditionally required compliance with fewer standards—just 29 in total.

ASV Scans and PCI DSS v4.0 SAQ A

What are ASV Scans? ASV scans are designed to identify security vulnerabilities on external systems that could be exploited by attackers to compromise sensitive payment data. Previously, SAQ A did not require these scans, but with PCI DSS v4.0, this has changed. 

Now, businesses completing SAQ A must undergo vulnerability scans by an ASV at least every 90 days.

“Even if your business uses a redirect or iFrame for payments, you will still need these scans.” 

This is because cybercriminals often exploit weak spots in systems, and unpatched servers hosting your payment page could be targeted to inject malicious code or replace redirects with fraudulent checkout pages, potentially sending payment details to criminals.

This new requirement helps protect your website and your customers by identifying and addressing security issues before they can be exploited.

Why Did The PCI Council Mandate ASV Scans for SAQ A Merchants?

The PCI Council mandated ASV scans for SAQ A merchants to enhance the security of payment card data. While SAQ A merchants may not store or process cardholder data directly, their websites and systems still play a critical role in facilitating transactions. By introducing ASV scans, the PCI Council aims to close security gaps in the broader payment ecosystem, ensuring that merchants maintain secure environments even when using outsourced payment processing.

 The PCI Council has found that many data breaches occur due to: 

• Weak passwords 
• Misconfigured network devices
• Other security flaws (that can be identified through ASV scans.) 

By mandating ASV scans for SAQ A merchants, the PCI Council is taking a proactive approach to security, rather than waiting for a data breach to occur before taking action.

What are the PCI DSS v4.0 SAQ A ASV Scan Requirements?

As specialists in PCI DSS, we want to highlight the changes introduced in this version that could impact businesses using SAQ A for their compliance, especially those who have done so in the past or are planning to in the future. This article will provide an overview of the SAQ A and its new ASV scanning requirements to help you prepare for these changes when you start filling out the questionnaire.

Best Practices for PCI DSS ASV Scans

With these new requirements in place, here are some recommended best practices to help businesses meet compliance:

• Expand the scope of your ASV scans beyond just the payment page to include all relevant systems.
• Whitelist trusted iFrame sources to minimize the risk of third-party interference.
• Monitor your payment service provider’s compliance with PCI standards to ensure they’re not compromising your compliance efforts.
• Address vulnerabilities quickly, especially high-risk findings that could be exploited.
• Ensure that your ASV is PCI SSC-approved and properly trained to meet the rigorous standards required for PCI compliance.
• Document your scanning processes to streamline future scans and ensure you’re prepared for compliance audits.
• Consider scanning every 30 days instead of quarterly to catch vulnerabilities sooner.
• Test your redirects and iFrames to ensure they are secure and functioning correctly.
• Stay informed about ongoing changes in PCI DSS and leverage available tools to protect your business.

Securisea's ASV Scanning Services

Securisea is an Approved Scanning Vendor that offers PCI ASV scanning services to merchants of all sizes. Securisea specializes in helping merchants meet the requirements of the ASV scan mandate and maintain PCI compliance. Securisea's ASV scanning services include regular on-demand scans, annual scans for merchants using SAQ A, and vulnerability scanning. Securisea’s goal through this service is to protect consumers from the potential financial and logistical burdens of a data breach.

Securisea Can Help with PCI DSS v4.0

At Securisea, we understand that navigating the complexities of PCI DSS v4.0 can be overwhelming, but it doesn’t have to be. Our team of experts is here to guide you every step of the way, from understanding new requirements like ASV scans to ensuring you meet all compliance standards with confidence. Whether you're starting your PCI journey or transitioning to the latest version, Securisea can provide the expertise and solutions you need to secure your business and protect your customers. Contact us today to get started on your path to PCI DSS v4.0 compliance and safeguard your business for the future.

DNSSEC (Domain Name System Security Extensions) is a feature of the Domain Name System (DNS) that verifies the authenticity of data in responses from authoritative DNS servers. It's a key requirement for cloud service providers (CSPs) to achieve and maintain Authority to Operate (ATO) for FedRAMP.

The DNS is essentially the phonebook of the internet, translating human-readable domain names (like securisea.com) into IP addresses that computers use to access websites. However, traditional DNS is inherently vulnerable to attacks like DNS spoofing and cache poisoning, where attackers can redirect users to malicious sites without their knowledge. DNSSEC adds a layer of cryptographic protection to DNS lookups, ensuring that the information returned by a DNS query is authentic and has not been tampered with. For organizations seeking FedRAMP compliance, implementing DNSSEC is essential to protect against these threats and maintain the integrity of their online services.

DNSSEC Requirements for FedRAMP certification

The FedRAMP Readiness Assessment Report includes the following questions in relation to your organization's DNSSEC configuration:

• Does the system’s external DNS solution support DNS Security (DNSSEC) to provide origin authentication and integrity verification assurances? This applies to the controls SC-20, SC-21, and SC-22 in the SSP." (section 4.1)
  
  
• Did the 3PAO [third-party assessment organization] verify that the external DNS server replies with valid DNSSEC responses and that the recursive server is within a FedRAMP Authorized boundary, makes DNSSEC requests for domains outside the boundary, and that DNS calls maintain DNSSEC authentication and integrity? [SC-20, SC-21]" (section 4.2)

Here's how DNSSEC helps:

Prevents DNS Spoofing and Cache Poisoning: DNSSEC adds a layer of security to the DNS by enabling the authentication of DNS responses. This prevents attackers from injecting false DNS data into the resolver's cache (cache poisoning) or redirecting traffic through DNS spoofing, which could lead to man-in-the-middle attacks.

Data Integrity Through Digital Signatures: DNSSEC ensures that the data returned by the DNS server is authentic and has not been altered in transit. It does this by using public-key cryptography to sign DNS data. When a DNS resolver receives a response, it checks the signature with the public key published in the DNS. If the signature is valid, the resolver knows the data has not been tampered with.

Enhanced Trustworthiness: For cloud service providers, ensuring the integrity of DNS data is crucial because any tampering could lead to users being redirected to malicious sites or services. DNSSEC helps maintain the trustworthiness of the DNS infrastructure by ensuring that users are directed to the correct IP addresses for cloud services.

Protection Against Downtime and Data Breaches: By securing the DNS infrastructure, DNSSEC helps cloud service providers protect against potential downtime caused by DNS attacks and prevents unauthorized access to sensitive data that could result from DNS hijacking.

Support for Secure Authentication Mechanisms: DNSSEC lays the foundation for additional security mechanisms, such as DANE (DNS-based Authentication of Named Entities), which can be used to ensure secure connections to cloud services by verifying the authenticity of SSL/TLS certificates.

How Securisea Can Help with DNSSEC and FedRAMP certification

Achieving and maintaining FedRAMP compliance is no small task, and DNSSEC is just one piece of the puzzle. As cybersecurity and compliance experts, Securisea provides comprehensive services to help your organization navigate the complexities of FedRAMP, including the implementation and management of DNSSEC.

FedRAMP Advisory. Considered by many to be the most comprehensive and challenging security program in the world, many firms seeking a FedRAMP ATO chose to retain a 3PAO company to assist with building their compliance program. At Securisea, we have the experience and expertise to build out an efficient and cost effective compliance program that enhances overall security posture while de-risking the ATO application.

FedRAMP Readiness Assessment. For most cloud service providers, the FedRAMP Readiness Assessment is the fastest route to being listed in the Federal Marketplace. This engagement is especially beneficial for companies seeking an agency sponsor to obtain their first ATO and is seen by many as a requirement for unlisted services that wish to apply for a P-ATO.

FedRAMP Assessment. Undergoing a FedRAMP Assessment is the final step in achieving your Agency or Provisional Authorization to Operate (ATO). As a 3PAO, Securisea is one of a select number of firms qualified to represent your compliance program to your Agency or Joint Authorization Board contact.

Ready to tackle FedRAMP?Contact Securisea today to learn more about how we can help get the ball rolling with our FedRAMP Advisory Services.