SOC 2 CC2.2: internal communication, explained for startups

What usually proves it

An auditor wants records from the period being examined, pulled from the systems that hold them rather than written up afterwards. Dates matter. A record with a date and a named owner carries more weight than a screenshot with neither. For CC2.2, the usual records are these.

• Policies published on an internal wiki or drive
• Onboarding materials that cover security
• Policy acknowledgment records and training completions

What Polara asks about it

The free readiness assessment asks 3 questions that bear on CC2.2. A yes becomes a task to show the proof. A no becomes a task to fix the gap, with the steps written out.

• Are security roles and responsibilities documented and communicated? If yes, show it: responsible, accountable, consulted and informed (RACI) matrix, job descriptions with security duties, org chart highlighting security roles, or role responsibility document. If no, the fix: document security roles and responsibilities in the information security policy and communicate them to all personnel.
• Security awareness training at hire and annually? If yes, show it: security training completion report, learning platform export, phishing simulation summary, or training acknowledgement record. If no, the fix: assign security awareness training at hire and annually, and retain the completion record.

It also asks, for context:

• Whistleblower or ethics reporting channel (email, hotline, or anonymous form).

Policies, templates and connected evidence

A policy states the rule, a template gives you the record to keep, and a connected system pulls the proof from the source. An auditor checks that the three agree: the cadence in the policy, the dates in the record and what the system shows.

In the policy pack, the Human Resources Security Policy and Information Security Policy cover CC2.2.

Free templates that help, printed in full with Word, PDF or Excel downloads:

• Information security policy template
• Security roles and responsibilities template
• Security awareness program template
• Security training log template

If you also run ISO 27001, the Annex A controls A.5.1, security policies, A.5.10, acceptable use, A.6.3, security training and A.6.8, reporting security events ask for overlapping evidence. One record can serve both when it names what it proves.

Is it in your scope?

Yes, always. CC2.2 is one of the 33 common criteria, and the common criteria are in every SOC 2 report, Type 1 or Type 2. The common criteria. Every SOC 2 report covers them, whatever else you add: governance, risk, access, operations, change and vendors. Most of the work in any SOC 2 sits here.

Polara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.

Communication and information: the criteria around it

CC2.2 is one of 3 criteria in communication and information, CC2.1 to CC2.3. Reading a group together shows how its outcomes fit, and one record often serves more than one of them.

• CC2.1, reliable information
• CC2.2, this page
• CC2.3, external communication

Before it: CC2.1, reliable information. After it: CC2.3, external communication. All the criteria are on the Trust Services Criteria page, grouped by category.