How to Write All 14 SOC 2 Policies (with Templates)
The 14 policies every SOC 2 audit requires. What each covers, how to write it, and the key elements auditors check in each document.
- SOC 2 does not specify a required policy list, but auditors typically expect 12–16 policies depending on scope.
- Every policy must be approved (signed by a named executive), versioned, and reviewed annually.
- The 14 policies cover all major control categories: people, technical, operational, and governance.
- Policy quality matters more than length — a clear, accurate 3-page policy outperforms a vague 12-page one.
- Policies must match practice — auditors compare what policies say to what evidence shows.
In this guide
Policy Requirements for SOC 2
SOC 2 CC2.1 requires that management establishes policies and procedures to meet its objectives. CC2.2 requires that these policies are communicated to personnel with responsibility for implementing them. CC2.3 requires that third parties are informed of relevant policies.
There is no official AICPA-mandated policy list. Auditors derive expected policies from the Trust Services Criteria — each criterion you include in scope implies the need for documented policies covering that area.
The 14 Policies
1. Information Security Policy — the umbrella document establishing management commitment, scope, roles, and the policy hierarchy. References all other policies. 2. Access Control Policy — governs user provisioning, deprovisioning, MFA requirements, privileged access, and access review frequency. 3. Encryption Policy — defines when data must be encrypted at rest and in transit, acceptable encryption standards (AES-256, TLS 1.2+), and key management requirements.
4. Incident Response Policy — defines incident categories, severity levels, response team, phases, and communication requirements. 5. Change Management Policy — governs the process for changes to production systems: approval requirements, testing, emergency change process. 6. Vulnerability Management Policy — defines vulnerability scanning frequency, CVSS severity thresholds, remediation SLAs, and penetration test frequency.
7. Risk Assessment Policy — describes the risk assessment methodology, frequency (annual minimum), risk register maintenance, and risk acceptance process. 8. Vendor Management Policy — defines vendor risk tiering, review frequency, evidence requirements (SOC 2 reports), and DPA requirements. 9. Data Classification and Handling Policy — defines sensitivity levels (Public, Internal, Confidential, Restricted) and required handling controls for each level.
10. Backup and Recovery Policy — defines backup frequency, retention, offsite/encrypted backup requirements, and RTO/RPO targets. Requires evidence of periodic backup restore testing. 11. Business Continuity and Disaster Recovery Policy — defines BCP/DRP scope, recovery priorities, testing frequency, and communication plan. 12. Acceptable Use Policy — governs employee use of company systems, acceptable and prohibited activities, personal device policy, and consequences of violation.
13. Physical Security Policy — governs data centre access (typically reference your cloud provider's controls), office physical security, workstation lock requirements, and clean desk policy. 14. Privacy Policy — describes personal data collection, use, retention, sharing, and individual rights. Only strictly required for SOC 2 if you include the Privacy Trust Services Criterion in scope.
Writing Tips
Write in present tense: "The company requires MFA for all users with console access" — not "The company will require..." Present tense describes current practice.
Be specific about frequencies and thresholds. "Access reviews are conducted quarterly" is better than "access reviews are conducted regularly." "Vulnerabilities with CVSS 7.0+ are remediated within 30 days" is better than "critical vulnerabilities are addressed promptly."
Include a scope statement in every policy. This makes audit testing cleaner — auditors know exactly who the policy covers.
Approval and Version Control
Each policy must be approved by a named executive — not just "management." Include the title, approval date, and an expiry/next-review date.
Version numbering: 1.0 for initial approval, 1.1 for minor updates, 2.0 for major revisions. Maintain a change history table at the end of each policy: version, date, description of change, author.
Store policies in a version-controlled location: Google Drive with version history, Confluence with page history, or GitHub for document management. The compliance tool (AuditPath) provides a policy library with version tracking built in.
Employee Acknowledgement
CC2.2 requires policies to be communicated to personnel. Document this communication. Methods: annual security awareness training that includes policy review and a completion quiz, a document acknowledgement system (DocuSign, Workday), or a policy review checklist in your onboarding process.
For new employees: policies should be reviewed as part of onboarding within the first week. For existing employees: annual review and re-acknowledgement, typically tied to your annual security awareness training cycle.
Store acknowledgement records in your HRIS or compliance tool. Auditors will ask for evidence that employees have been informed of policies — a record showing 95%+ of employees have acknowledged within the past 12 months satisfies this requirement.
Frequently Asked Questions
Are there free SOC 2 policy templates available?
Do all 14 policies need to be ready for a Type I audit?
How long should each policy be?
Can we use one policy document for multiple SOC 2 areas?
What if our practice does not match our policy?
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