Do You Have to Do Phishing Simulations to Comply with SOC 2 Common Criteria?
August 29, 2023
The below is a summary of the post.
Phishing attacks are a major concern for organizations today, as perpetrators use deceptive emails and fraudulent websites to compromise sensitive data or gain unauthorized access to systems. In response, many organizations have turned to phishing simulations to train employees and gauge their susceptibility to such attacks. But does conducting phishing simulations help companies comply with the SOC 2 common criteria? In this blog post, we will explore the relationship between phishing simulations and SOC 2 compliance.
The SOC 2 (System and Organization Controls 2) report is a comprehensive evaluation of an organization's information systems, which focuses on five Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy. An organization must meet the relevant common criteria to achieve SOC 2 compliance.
While phishing simulations are not explicitly mentioned in the SOC 2 common criteria, they can play a vital role in maintaining and improving an organization's security posture. A robust security awareness program, which may include phishing simulations, can help an organization meet the requirements of the SOC 2 Security Trust Services Criteria.
Two specific common criteria in the SOC 2 Security Trust Services Criteria are particularly relevant to phishing simulations: risk management (CC3.1) and employee training (CC6.4).
CC3.1 states that an organization must identify and assess risks to the confidentiality, integrity, and availability of the information systems. This includes identifying potential threats, such as phishing attacks, and implementing controls to mitigate those risks. By conducting phishing simulations, an organization can gauge its employees' susceptibility to phishing attacks and determine if additional training or controls are necessary to mitigate the risk.
CC6.4 requires organizations to provide security awareness training to employees. Phishing simulations can be an effective component of a security awareness program, helping to educate employees about the dangers of phishing attacks and how to identify and respond to them. By including phishing simulations in their training programs, organizations can demonstrate their commitment to employee training, thereby satisfying this SOC 2 common criteria requirement.
Conducting phishing simulations can also help an organization demonstrate the effectiveness of its security training to SOC 2 auditors. By measuring employees' performance in the simulations (e.g., click rates, reporting rates), the organization can identify areas where additional training may be required and show improvement over time. This tangible evidence of training effectiveness can be valuable during a SOC 2 audit.
While phishing simulations are not explicitly required in the SOC 2 common criteria, they can indirectly contribute to satisfying specific requirements. For example, conducting simulations can help identify weaknesses in an organization's security controls, which, in turn, can lead to improvements in areas such as access controls (CC5), system operations (CC7), and incident response (CC8).
In summary, while phishing simulations are not explicitly required by SOC 2 common criteria, they can be a valuable tool for organizations seeking to comply with the security requirements. A strong security awareness program, which may include phishing simulations, can help organizations meet the risk management and employee training requirements of the SOC 2 Security Trust Services Criteria. Furthermore, phishing simulations can demonstrate the effectiveness of security training and indirectly contribute to satisfying other SOC 2 common criteria.
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