OUR THOUGHTS ON:

ASEC Issues Exposure Draft to Revise TSP Section 100, Trust Services Principles and Criteria for SOC 2 Reports

SSAE 18/SOC

By Troy Fine

On June 15, the Assurance Services Executive Committee (ASEC) of the American Institute of CPAs (AICPA) issued an exposure draft proposing revisions to TSP section 100, Trust Services Principles and Criteria (TSPC) for Security, Availability, Processing Integrity, Confidentiality and Privacy for Service Organization Control (SOC) 2 reports.  These revisions are part of a continual effort from the ASEC to update the TSPC and keep them relevant in the changing technology and business environment.  The proposed effective date for the revised TSPC is for periods ending on or after March 15, 2016 with early implementation permitted.

The most significant proposed change is the creation of a new set of privacy criteria.  The current privacy criteria, which follow the “Generally Accepted Privacy Principles (GAPP)” will be superseded by the new set of privacy criteria.  The new set of privacy criteria will be made up of the set of common criteria and the additional criteria for the privacy principal.  Previously, there was no relationship between the common criteria and GAPP.  In addition, the “Illustrative Risks and Controls” section of TSP section 100 will be revised to include illustrative risks and additional illustrative controls related to the new set of privacy criteria. 

Proposed Changes to TSP Section 100, Trust Services Principles and Criteria for Security, Availability, Processing, Integrity, Confidentiality and Privacy for Service Organization Control (SOC) 2 Reports:

  • Clarification of criteria CC3.1 and CC3.3 to include potential threats that arise from the use of third parties;
  • Two additional criteria for Confidentiality, C1.7 and C1.8, to address retention and disposal of confidential information;
  • Minor revisions to the wording of existing criteria to provide clarity;
  • Revisions of explanatory paragraphs of TSP section 100 to provide clarity.

Practitioners and service organizations are encouraged to review the proposed changes and to provide comments by August 15, 2015. 

Please contact our SOC experts in Pittsburgh, PA or Columbus, OH to find out how the proposed revisions to TSP section 100 will affect your organization and your SOC 2 report and visit our SOC page for more information on SOC reports and how they can help your organization.

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