Perform Ongoing and Separate Evaluations
Plain English Translation
Under SOC 2 CC.1, organizations must conduct ongoing and separate evaluations to ensure their internal controls are actively working. This SOC 2 Type 2 internal control evaluation process involves a mix of real-time automated monitoring and periodic manual reviews, such as internal audits. By implementing a robust SOC 2 CC.1 monitoring activities control, the organization can detect security events, system failures, and compliance gaps, confirming that safeguards remain present and functioning as the business environment changes.
Technical Implementation
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Required Actions (startup)
- Implement basic capacity monitoring and security event logging on critical infrastructure.
- Perform a lightweight annual internal control review or self-assessment by control owners.
Required Actions (scaleup)
- Deploy centralized logging and alerting dashboards that notify operations personnel of anomalies automatically.
- Engage independent third parties for annual penetration testing to serve as a separate evaluation.
CC.1 is the SOC 2 CC.1 monitoring activities control that requires organizations to select, develop, and perform evaluations. It ensures that the components of internal control are present and functioning to achieve organizational objectives.
Organizations learn how to perform ongoing evaluations for SOC 2 CC.1 by integrating monitoring tools directly into business processes. This includes utilizing real-time dashboards and alerting systems to track security events, network performance, and system capacity.
Examples of ongoing evaluations include automated vulnerability scanning, daily capacity monitoring alerts, and real-time security event logging. These SOC continuous monitoring and evaluation strategies detect anomalies as they occur.
The main difference between ongoing and separate evaluations SOC requires is frequency and integration. Ongoing evaluations are built into daily operations for real-time feedback, while separate evaluations are periodic, objective reviews like internal audits or penetration tests.
Ongoing evaluations should occur continuously or in real-time, integrated into standard business processes. Separate evaluations are performed periodically, with their scope and frequency adjusted based on risk and the rate of change in the environment.
Yes, penetration testing and independent certifications are explicitly recognized as valid examples of separate evaluations in SOC compliance. They provide an objective, external perspective on the effectiveness of security controls.
Organizations use centralized logging solutions, automated vulnerability scanners, and continuous control monitoring platforms. These tools provide the necessary data to perform ongoing evaluation methods for SOC 2 controls efficiently.
WatchDog Security's Compliance Center can automate evidence collection for SOC 2 evaluations, streamlining the process of conducting continuous internal control assessments. By integrating real-time monitoring tools, it ensures that controls are actively functioning and provides compliance teams with the necessary documentation to support audits.
With tools like WatchDog Security's Vulnerability Management and Posture Management, organizations can automate vulnerability scanning and remediation processes. These tools serve as separate evaluations, ensuring that internal controls are assessed periodically and that any issues are identified and addressed before they impact security.
WatchDog Security's Compliance Center can automate evidence collection for SOC 2 evaluations, streamlining the process of conducting continuous internal control assessments. By integrating real-time monitoring tools, it ensures that controls are actively functioning and provides compliance teams with the necessary documentation to support audits.
With tools like WatchDog Security's Vulnerability Management and Posture Management, organizations can automate vulnerability scanning and remediation processes. These tools serve as separate evaluations, ensuring that internal controls are assessed periodically and that any issues are identified and addressed before they impact security.
"COSO Principle 16: The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning."
| Version | Date | Author | Description |
|---|---|---|---|
| 1.0.0 | 2026-02-23 | WatchDog Security GRC Team | Initial publication |