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SOC 247
ITSP.10.17198
ISO 42001soon
ISO 27001soon
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33 controls
CC1.1
Commitment to integrity and ethical values
Control Environment
6 evidence2 controls
CC1.2
Board independence and oversight of internal control
Control Environment
3 evidence1 control
CC1.3Organizational structure, reporting lines, and authoritySOC 2Control Environment
Official Requirement
Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives.
There is a clear org chart that shows who owns what. Security responsibilities are assigned to named individuals or roles, not left as everyone's problem. The person responsible for the security program has the authority to enforce policies and escalate issues. Auditors want to trace every significant control to a named owner.
These are typical controls and implementation steps. Your systems and environment may differ.
Typical Control Published org chart with defined security ownership and RACI
Implementation Steps
Publish a current organizational chart that is accessible to all staff and updated when reporting lines change
Assign a named Information Security Officer or equivalent role in writing; document their responsibilities in a job description or policy
Map security responsibilities in the Information Security Policy: who owns each control domain (access control owner, incident response lead, vendor risk owner)
Produce a RACI matrix for key security domains so auditors can quickly verify that every control area has an accountable owner
Tools / Systems
Confluence / Notion (org chart and role definitions)Google Workspace / Microsoft 365 (org chart via directory)Lucidchart (RACI and org diagrams)GRC platform (e.g., Vanta, Drata, your GRC platform, Scrut)
Typical Control Published org chart with defined security ownership and RACI
Evidence Artifacts
Current organizational chart with date of last update
Job description or policy section defining the Information Security Officer responsibilities
RACI or responsibility assignment matrix for security domains, signed by management
📅Org chart updated with each structural change; reviewed and re-confirmed annually
Cross-framework mappings coming in v1.1
When we add ISO 42001 and ISO 27001, you'll see which controls map to this criterion.
ISO
ISO 42001
AI Management Systems
ISO
ISO 27001
Information Security
Mapping data will appear here automatically when the frameworks are published.
CC1.4
Commitment to attract, develop, and retain competent individuals
Control Environment
6 evidence2 controls
CC1.5
Accountability for internal control responsibilities
Control Environment
3 evidence1 control
CC2.1
Obtains or generates and uses relevant quality information
Communication and Information
3 evidence1 control
CC2.2
Internal communication of information to support internal control
Communication and Information
6 evidence2 controls
CC2.3
External communication regarding matters affecting internal control
Communication and Information
4 evidence1 control
CC3.1
Specifies objectives with sufficient clarity
Risk Assessment
3 evidence1 control
CC3.2
Identifies and analyzes risks to achievement of objectives
Risk Assessment
3 evidence1 control
CC3.3
Considers potential for fraud in assessing risks
Risk Assessment
3 evidence1 control
CC3.4
Identifies and assesses significant changes
Risk Assessment
3 evidence1 control
CC4.1
Selects, develops, and performs ongoing and separate evaluations
Monitoring Activities
6 evidence2 controls
CC4.2
Evaluates and communicates internal control deficiencies
Monitoring Activities
3 evidence1 control
CC5.1
Selects and develops control activities that mitigate risks
Control Activities
3 evidence1 control
CC5.2
Selects and develops general controls over technology
Control Activities
6 evidence2 controls
CC5.3
Deploys control activities through policies and procedures
Control Activities
3 evidence1 control
CC6.1
Logical access security infrastructure
Logical and Physical Access Controls
11 evidence3 controls
CC6.2
Registration and authorization prior to issuing credentials
Logical and Physical Access Controls
6 evidence2 controls
CC6.3
Role-based access management
Logical and Physical Access Controls
6 evidence2 controls
CC6.4
Physical access restrictions
Logical and Physical Access Controls
3 evidence1 control
CC6.5
Disposal and destruction of information assets
Logical and Physical Access Controls
3 evidence1 control
CC6.6
Controls against threats from outside system boundaries
Logical and Physical Access Controls
8 evidence2 controls
CC6.7
Restricts transmission and movement of information
Logical and Physical Access Controls
7 evidence2 controls
CC6.8
Controls to prevent or detect unauthorized software
Logical and Physical Access Controls
6 evidence2 controls
CC7.1
Detection and monitoring for vulnerabilities
System Operations
8 evidence2 controls
CC7.2
Monitoring for anomalies and security events
System Operations
4 evidence1 control
CC7.3
Evaluation of security events as security incidents
System Operations
4 evidence1 control
CC7.4
Incident response program
System Operations
4 evidence1 control
CC7.5
Recovery from security incidents
System Operations
4 evidence1 control
CC8.1
Authorized change management process
Change Management
8 evidence2 controls
CC9.1
Risk mitigation for business disruptions
Risk Mitigation
4 evidence1 control
CC9.2
Vendor and business partner risk management
Risk Mitigation
4 evidence1 control
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On-premises implementation and evidence
Published org chart with defined security ownership and RACI
Implementation steps
Maintain an org chart on the intranet or shared drive; confirm it reflects actual reporting lines
Document security role assignments in a policy or RACI matrix: responsible, accountable, consulted, and informed for each security domain
The SOC 2 system description (required in the auditor's report) must include the organizational structure; prepare this narrative using the org chart as source material
Tools / systems
Org chart tool (Lucidchart, draw.io, or Visio)
RACI matrix (spreadsheet)
Shared drive (document storage)
GRC platform (e.g., Vanta, Drata, your GRC platform, Scrut)
Evidence artifacts
Org chart document with effective date
RACI matrix or Information Security Policy section mapping control ownership to named roles
SOC 2 system description narrative referencing the organizational structure
Evidence frequency: Maintained continuously; reviewed annually or upon significant org changes
