SOC 2 CC6.2: user provisioning, 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 CC6.2, the usual records are these.

• Access request tickets with approvals
• Offboarding checklists with removal dates
• A list of terminated users compared with active accounts

What Polara asks about it

The free readiness assessment asks 6 questions that bear on CC6.2. A yes becomes a task to show the proof. A no becomes a task to fix the gap, with the steps written out.

• Role-based access for production systems? If yes, show it: AWS identity and access management (IAM) groups and roles screenshot, Okta groups list, Azure Active Directory group assignments, or role-based access control (RBAC) matrix export. If no, the fix: define production roles, assign access through those roles only, and export the role configuration.
• User access removed within 24 hours of termination? If yes, show it: offboarding ticket, deprovisioning log from your human resources system to Okta, access removal checklist, or terminated user access report. If no, the fix: add a 24 hour access removal step to the offboarding checklist and retain the completed checklist for each departure.
• How often is a documented review of all user access to production performed? If yes, show it: signed access review record, a user list export carrying the reviewer name and date, the access review ticket with the removals it produced, or an identity provider access review report. If no, the fix: review every production account at least quarterly and retain the completed review with its reviewer and its date.
• Is access to production approved by a named manager before it is granted? If yes, show it: access request ticket showing the approver and the date, an identity provider access request record, an approval email saved to the ticket, or a signed access request form. If no, the fix: require a named manager to approve each production access request and retain the approval record.
• Do you follow a documented offboarding checklist that records access revocation for each departure? If yes, show it: signed offboarding record, a completed offboarding ticket showing each system disabled with its timestamp, or a deprovisioning log for a departed employee. If no, the fix: adopt an offboarding checklist that records every access revocation, and retain the completed checklist for each departure.

It also asks, for context:

• SSO used for SaaS apps?

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 Access Control Policy and Human Resources Security Policy cover CC6.2.

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

• Access control policy template
• User access review template
• Offboarding checklist template
• Access control matrix template

Connected systems that pull evidence for it:

• Amazon Web Services, IAM users: who has access, with each user's multi-factor authentication status and last login.
• Amazon Web Services, IAM password policy: the account-wide password requirements, or that none is set.
• GitHub, Organization two-factor enforcement: whether two-factor authentication is required for every organization member.
• Google Workspace, 2-Step Verification status: per-user 2-Step Verification enrollment, summarized for the domain.
• Okta, Users and last sign-in: Okta users with their status and last sign-in time.
• Okta, Deprovisioned users: users deprovisioned in the collection window, with the date their status changed.
• Microsoft Entra ID, Users and last sign-in: directory users with their enabled status, user type and last sign-in.
• Linear, Workspace members: Workspace members with their active, admin and guest status.
• Jira, Site users: users on the Jira site with their active status and account type.
• Slack, Workspace members: Workspace members, admins, guests and deactivated accounts.

If you also run ISO 27001, the Annex A controls A.5.11, returning assets, A.5.16, identities and accounts, A.5.18, granting and removing access and A.6.5, duties after leaving 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 role-Based Access Control. The fix: define access roles and document who has what level of access. The proof: access control matrix or IAM role listing showing user-to-role mappings.

An auditor asks two things about it. Is there a documented role-based access control model? Are user access levels defined and mapped to roles in the system?

Is it in your scope?

Yes, always. CC6.2 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.

Logical and physical access: the criteria around it

CC6.2 is one of 8 criteria in logical and physical access, CC6.1 to CC6.8. Reading a group together shows how its outcomes fit, and one record often serves more than one of them.

• CC6.1, logical access
• CC6.2, this page
• CC6.3, least privilege
• CC6.4, physical access
• CC6.5, data and device disposal
• CC6.6, network boundaries
• CC6.7, data in transit
• CC6.8, malware prevention

Before it: CC6.1, logical access. After it: CC6.3, least privilege. All the criteria are on the Trust Services Criteria page, grouped by category.