What are the Trust Service Criteria?
The Trust Service Criteria are the five categories a SOC 2 report can cover: Security, which is always included, and optionally Availability, Confidentiality, Processing Integrity and Privacy. They are set by the AICPA, whose official name for them is the Trust Services Criteria.
The five categories
Each category is a set of criteria, and each criterion comes with points of focus that describe what auditors typically look for. The points of focus are guidance. The criteria are what the auditor reports against.
- Security. Protection against unauthorised access, unauthorised disclosure and damage to systems. Always in scope.
- Availability. Whether the system is available for operation and use as committed, including capacity, backup and recovery.
- Confidentiality. Protection of information designated as confidential, such as customer business data, through to its disposal.
- Processing Integrity. Whether system processing is complete, valid, accurate, timely and authorised.
- Privacy. How personal information is collected, used, retained, disclosed and disposed of, in line with the organisation’s commitments.
The common criteria
Security is made up of the common criteria, so called because they apply whichever other categories are added. The first five groups carry the 17 principles of the COSO 2013 internal control framework. The remaining groups cover areas specific to technology. When you add Availability, Confidentiality, Processing Integrity or Privacy, their criteria are tested on top of the common criteria, never instead of them.
- CC1 to CC5. Control environment, communication and information, risk assessment, monitoring activities and control activities.
- CC6. Logical and physical access controls.
- CC7. System operations, including detecting and responding to incidents.
- CC8. Change management.
- CC9. Risk mitigation, including risk from vendors and business partners.
Choosing which to include
Include a category only when customers expect it or your service depends on it. Availability is common for infrastructure and platform services with uptime commitments. Confidentiality suits companies that hold customers’ sensitive business data. Processing Integrity fits payments, payroll and other services where a calculation error causes real harm. Privacy is chosen less often, and many organisations cover personal data through their GDPR or wider privacy programme instead.
Each category you add means more controls to run and more evidence for the auditor to test, so adding all five to a first report is rarely worth it. Categories can be added to later reports as customers ask for them.
Questions
Trust Service Criteria, answered
Is it Trust Service Criteria or Trust Services Criteria?
The AICPA’s term is Trust Services Criteria. Trust Service Criteria is a common variant, and both mean the same thing.
Do the Trust Services Criteria list the controls we need?
No. They set out what controls must achieve. Each organisation designs its own controls to meet them, and the auditor tests those controls.
Do the criteria map to ISO 27001?
Yes. The AICPA has published mappings from the Trust Services Criteria to other frameworks, including ISO 27001, and much of the evidence for one supports the other.
Working through this for an audit?
Talk it through with someone who has run the audit before, or look up another term.
- Each customer workspace has its own database
- Every change written to a tamper-evident activity log
- Auditors get scoped, read-only access
- AI suggestions wait for a person to accept them