SOC 2 CC5.3: policies and procedures, 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 CC5.3, the usual records are these.

• Approved policies with owners and review dates
• Policy acknowledgment records
• Evidence that the procedures in each policy ran

What Polara asks about it

The free readiness assessment asks 3 questions that bear on CC5.3. A yes becomes a task to show the proof. A no becomes a task to fix the gap, with the steps written out.

• Has management formally approved the security and compliance program in the last 12 months? If yes, show it: board resolution, signed policy approval page, executive approval email, or meeting minutes. If no, the fix: obtain and minute management or board approval of the security program before the examination date.
• Does management review the overall security and compliance program at least annually? If yes, show it: annual security review meeting notes, steering committee minutes, security program update deck, or executive approval email. If no, the fix: schedule an annual management review of the security program and minute the outcome.
• Is there a process to track and close remediation items from audits, incidents, tests, or reviews? If yes, show it: Jira board for security remediation, Linear remediation project, ServiceNow remediation queue, or spreadsheet tracker. If no, the fix: track remediation items in a ticketing system with owners and due dates until each is closed.

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 Information Security Policy and Risk Management Policy cover CC5.3.

If you also run ISO 27001, the Annex A controls A.5.1, security policies, A.5.36, checking policy compliance and A.5.37, written procedures ask for overlapping evidence. One record can serve both when it names what it proves.

Is it in your scope?

Yes, always. CC5.3 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.

Control activities: the criteria around it

CC5.3 is one of 3 criteria in control activities, CC5.1 to CC5.3. Reading a group together shows how its outcomes fit, and one record often serves more than one of them.

• CC5.1, choosing controls
• CC5.2, technology controls
• CC5.3, this page

Before it: CC5.2, technology controls. After it: CC6.1, logical access. All the criteria are on the Trust Services Criteria page, grouped by category.