SOC 2
AICPA framework for service organizations' data controls
GLBA
US federal law for financial privacy and safeguards
Quick Verdict
SOC 2 offers voluntary Trust Services audits for service providers proving controls, while GLBA mandates privacy notices and security programs for financial firms handling NPI. Companies adopt SOC 2 for market trust; GLBA avoids regulatory penalties.
SOC 2
System and Organization Controls 2
Key Features
- Trust Services Criteria with mandatory Security foundation
- Type 2 reports validate operating effectiveness over time
- Flexible scoping of optional criteria like Privacy
- AICPA CPA-attested assurance for service organizations
- Overlaps significantly with ISO 27001 HIPAA frameworks
GLBA
Gramm-Leach-Bliley Act (GLBA)
Key Features
- Designates Qualified Individual for security program oversight
- Requires written risk assessments and annual board reporting
- Mandates privacy notices and opt-out rights for NPI sharing
- Imposes 30-day breach notification for 500+ consumers
- Enforces vendor oversight and service provider safeguards
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
SOC 2 Details
What It Is
SOC 2, or System and Organization Controls 2, is a voluntary attestation framework developed by the American Institute of Certified Public Accountants (AICPA). It evaluates service organizations' commitments to Trust Services Criteria (TSC)—security, availability, processing integrity, confidentiality, and privacy—for systems handling customer data. The control-based methodology includes Type 1 (design at a point in time) and Type 2 (design plus operating effectiveness over 3-12 months).
Key Components
- Five TSCSecurity** (mandatory, CC1-CC9 common criteria), plus optional Availability (A1), Confidentiality (C1), Processing Integrity (PI1), Privacy (P1-P11).
- 50-100 controls per scope, with redundancy (2-3 per point).
- Built on COSO principles; CPA-attested reports.
Why Organizations Use It
Drives enterprise sales by streamlining due diligence (80-90% questionnaire coverage), unlocks markets, reduces breach liability, and signals maturity to investors. Voluntary yet market-mandated for SaaS/cloud providers; overlaps 80% with ISO 27001, aiding multi-framework efficiency and ROI via higher ACVs.
Implementation Overview
Phased approach: scoping/gap analysis (2-4 weeks), control deployment/automation (4-8 weeks), monitoring period (3-12 months), CPA audit (1-2 months). Targets data-handling service orgs (SaaS, fintech); scalable via tools like Vanta. Annual recertification with bridge letters.
GLBA Details
What It Is
The Gramm-Leach-Bliley Act (GLBA) is a US federal law enacted in 1999, establishing privacy and security standards for financial institutions. It mandates transparency in data sharing and a risk-based information security program via the Privacy Rule and Safeguards Rule, focusing on nonpublic personal information (NPI).
Key Components
- **Privacy RuleInitial/annual notices, opt-out rights for nonaffiliated sharing.
- **Safeguards RuleWritten security program with administrative, technical, physical controls; Qualified Individual oversight; risk assessments; vendor management.
- **Pretexting provisionsAnti-social engineering protections. Built on risk-based approach; no fixed control count; enforced by FTC for non-banks.
Why Organizations Use It
- Legal compliance for financial entities handling NPI.
- Mitigates breach risks, enforcement penalties (up to $100K/violation).
- Builds customer trust, enables ROI via IAM/automation.
- Competitive edge in data protection.
Implementation Overview
Phased roadmap: scoping, risk assessment, controls, testing. Applies to banks/non-banks; scalable by size; requires audits, annual reporting; no formal certification.
Key Differences
| Aspect | SOC 2 | GLBA |
|---|---|---|
| Scope | Trust Services Criteria: security, availability, confidentiality, privacy, processing integrity | Privacy notices, opt-outs, information security program for NPI |
| Industry | Service organizations (SaaS, cloud, tech), any size, US-centric | Financial institutions (broad: banks, fintech, tax firms), US |
| Nature | Voluntary AICPA audit framework, Type 1/2 reports | Mandatory federal regulation, FTC/banking agency enforcement |
| Testing | Annual pen tests, vulnerability scans, CPA audits (Type 2 over 3-12 months) | Periodic risk assessments, vulnerability/pen tests, no formal certification |
| Penalties | Loss of certification, market exclusion, no legal fines | Fines up to $100K/violation, criminal penalties, enforcement actions |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about SOC 2 and GLBA
SOC 2 FAQ
GLBA FAQ
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