Published on: Feb 23, 2017
How to Manage the 2016 SOC 2 Content Update
Standards and best practices in information security are never static. As technology evolves and corporate environments grow more complex, frameworks such as SOC 2 are updated to reflect new risks, regulatory expectations, and industry practices. In 2016, the American Institute of Certified Public Accountants (AICPA) released a major update to the Trust Services Principles (TSP)—now known as the Trust Services Criteria (TSC)—that reshaped the SOC 2 reporting landscape.
For service organizations, understanding the 2016 SOC 2 content update is essential to maintaining compliance, strengthening privacy practices, and ensuring audit readiness.
Why Was the SOC 2 Update Necessary?
The last significant revision before 2016 occurred in 2014, when the Common Criteria (CC) were introduced and applied across all principles. That update also added incremental criteria for Availability, Processing Integrity, and Confidentiality but left the Privacy principle largely untouched.
The 2016 update aimed to:
Eliminate outdated and redundant privacy criteria
Improve clarity across the framework by revising certain Common Criteria
Strengthen requirements around confidentiality and risk management
Introduce a modernized approach to privacy with the release of TSP Section 100
The result was a more streamlined, consistent, and risk-focused SOC 2 framework, designed to address emerging security and privacy challenges.
Key Changes in the SOC 2 2016 Content Update
The update brought several important revisions that organizations needed to adopt:
1. A More Defined Approach to Risk Management
The revised criteria require service organizations to adopt a structured risk management process. This includes:
Identifying both customer and third-party risks
Documenting how risks will be addressed and monitored
Demonstrating that controls are in place to mitigate identified risks
This change emphasized that risk management is not a one-time exercise but a continuous process.
2. New Confidentiality Criteria
Confidentiality now extends beyond access controls. The updated criteria focus on the data lifecycle, including:
Secure retention of sensitive information
Formal policies for secure data disposal
Alignment with contractual and regulatory confidentiality commitments
3. Restructured Privacy Criteria: TSP Section 100
The most significant change was the introduction of TSP 100, which replaced 64 pages of outdated guidance with a clear set of eight privacy criteria and 20 control objectives. These include:
Notice and Communication: Privacy commitments must be clearly communicated.
Choice and Consent: Consent for collecting, using, storing, or disclosing personal data must be explicit and documented.
Collection: Data must be collected in compliance with system requirements and privacy commitments.
Use, Retention, and Disposal: Personal data must be securely used, retained, and disposed of.
Access: Data subjects must be able to access, correct, or request copies of their personal data.
Disclosure and Notification: Sharing data with third parties requires formal permission.
Quality: Personal data must remain accurate, relevant, and complete.
Monitoring and Enforcement: Organizations must have processes for handling privacy-related inquiries, complaints, and disputes.
This shift simplified the privacy principle while aligning it more closely with other major compliance frameworks such as HIPAA and HITRUST.
How the SOC 2 2016 Update Impacts Organizations
For most organizations, the update was less disruptive than it initially appeared. The changes simplified privacy reporting and reduced redundancy across the framework. However, the update also introduced new compliance challenges:
Service organizations must now demonstrate a clear risk management process, supported by evidence from assessments and monitoring activities.
Data lifecycle management including retention and disposal became a compliance priority.
Organizations reporting on the Privacy principle needed to align with TSP 100, which required revisiting data subject rights, consent processes, and notification obligations.
The update also made it easier to leverage SOC 2 privacy criteria for multi-framework compliance. For example, organizations already managing HIPAA requirements could align their controls with SOC 2 to streamline audits and reduce duplicated efforts.
Preparing for SOC 2 Updates
While the 2016 update did not demand a complete overhaul of existing control frameworks, it reinforced the need for:
Ongoing risk assessments to identify evolving threats and compliance obligations
Documented policies and evidence supporting confidentiality and privacy practices
Integration of SOC 2 with other compliance frameworks, reducing audit complexity
Continuous monitoring and improvement, ensuring that privacy and security commitments remain up to date
By embedding these practices into their information security management systems, organizations can respond effectively not only to the 2016 update but also to future revisions of the SOC 2 framework.
Takeaways
The SOC 2 2016 content update serves as a reminder that compliance is not static, it evolves alongside technology, business operations, and regulatory expectations. Organizations that view compliance as more than just a checkbox exercise gain a competitive advantage:
Stronger customer trust through transparent privacy practices
Greater audit efficiency by aligning SOC 2 with frameworks like HIPAA or HITRUST
Improved risk resilience by embedding risk management into daily operations
By staying proactive and continuously refining compliance practices, service organizations can transform SOC 2 updates from a burden into a driver of stronger governance and security.
