SOC 2 CC3.2: risk identification, explained for startups
What CC3.2 asks you to show about risk identification, and what proves it.
You look for what could go wrong, at least once a year, and decide what to do about each risk. Each risk gets a likelihood, an impact and a treatment. A register that never changes reads as one nobody updates.1
CC3.2 is a common criterion, so it is part of every SOC 2 report.
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 CC3.2, the usual records are these.
- A dated risk assessment
- A risk register with likelihood, impact, owner and treatment
- Leadership sign off on the accepted risks
What Polara asks about it
The free readiness assessment asks 3 questions that bear on CC3.2. A yes becomes a task to show the proof. A no becomes a task to fix the gap, with the steps written out.
- Completed a formal information security risk assessment in the last 12 months? If yes, show it: risk assessment report with ratings, risk register spreadsheet, risk workshop notes, or risk review approval. If no, the fix: perform and document a formal risk assessment covering the in-scope system, with an owner for each identified risk.
- Where do you track identified risks and mitigation actions? If yes, show it: screenshot of risk register, Jira risk board, Linear risk tracker, or compliance tool risk dashboard. If no, the fix: stand up a risk register with an owner, likelihood, impact, and mitigation status for each identified risk.
It also asks, for context:
- List the top three risks that could impact your service commitments or system availability.
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 Risk Management Policy covers CC3.2.
Free templates that help, printed in full with Word, PDF or Excel downloads:
If you also run ISO 27001, the Annex A control A.5.7, threat intelligence ask for overlapping evidence. One record can serve both when it names what it proves.
Where it goes wrong
One gap a remediation playbook covers here is risk Assessment. The fix: create a risk register with identified risks scored by likelihood and impact. The proof: risk register export showing identified risks, scores, and owners.
An auditor asks two things about it. Is there a documented risk assessment methodology? Does a risk register exist with identified and scored risks?
Is it in your scope?
Yes, always. CC3.2 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.
Risk assessment: the criteria around it
CC3.2 is one of 4 criteria in risk assessment, CC3.1 to CC3.4. Reading a group together shows how its outcomes fit, and one record often serves more than one of them.
Before it: CC3.1, risk objectives. After it: CC3.3, fraud risk. All the criteria are on the Trust Services Criteria page, grouped by category.
Questions
What does SOC 2 CC3.2 ask a startup to show?
What evidence proves CC3.2?
Sources
Get audit-ready without a compliance team.
The readiness assessment is free, with no payment and no card. Star is $2,000 one time to get on the platform and close your gaps. Orbit is $7,800 a year, and your SOC 2 Type 2 audit is included in every contract year. You can be audit-ready starting at about a week.
Take the free assessmentPolara Labs is not a CPA firm. SOC 2 examinations are performed by independent licensed U.S. CPA firms.