SOC 2 P6.1: third party disclosures, 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 P6.1, the usual records are these.

• A list of third parties that receive personal data
• Data processing agreements
• Consent records where sharing requires consent

What Polara asks about it

The free readiness assessment asks one question that bear on P6.1. A yes becomes a task to show the proof. A no becomes a task to fix the gap, with the steps written out.

• Do you disclose personal information to third parties only for purposes in your notice, and keep a record of each disclosure? If yes, show it: list of third parties with the purpose of each disclosure, a disclosure log, or the subprocessor list published with the privacy notice. If no, the fix: list every third party that receives personal information and why, stop any disclosure outside your notice, and keep a disclosure record.

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 Privacy Program Policy covers P6.1.

Is it in your scope?

Only if you add Privacy. How you handle personal information across its life: notice, consent, collection, use, retention, access requests, disclosure and complaints. It is the heaviest category and assumes a privacy program already runs.

The scoping tool decides it with one question: Add it when you collect personal information about individuals and run a privacy program with a notice, consent and requests from the people it describes. When personal information is incidental to your service, Confidentiality is often the closer fit. Privacy notice, consent, collection and use limits, retention and deletion, access and correction requests, disclosures, breach notification and complaints.

Security is the default and always in scope. Adding Privacy in the assessment puts its 18 criteria into the report and the examination, and adds 14 questions to the assessment.

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

Disclosure and notification: the criteria around it

P6.1 is one of 7 criteria in disclosure and notification, P6.1 to P6.7. Reading a group together shows how its outcomes fit, and one record often serves more than one of them.

• P6.1, this page
• P6.2, disclosure records
• P6.3, unauthorized disclosures
• P6.4, processor commitments
• P6.5, processor breach notice
• P6.6, breach notification
• P6.7, disclosure reports

Before it: P5.2, correction requests. After it: P6.2, disclosure records. All the criteria, Security first, are on the Trust Services Criteria page, grouped by category.