SOC 2 Policy Writing Guide: Templates and Best Practices

After guiding dozens of companies through SOC 2 audits, we can tell you that the policy library is where most compliance programs quietly break down. Here is everything we have learned about writing policies that actually hold up under auditor scrutiny.

Your SOC 2 policy library is the documented foundation of your entire control environment. Auditors evaluate policies during every SOC 2 engagement — they verify that policies exist, are approved by management, are distributed to employees, are acknowledged, and most importantly, that they reflect actual organizational practices. The most common policy-related audit findings are not about missing policies — GRC platforms provide templates that cover the requirements. The findings are about policies that do not match reality: policies that describe processes the organization does not actually follow, policies that were never approved by management, and policies that employees signed but never read.

This guide covers the end-to-end process of writing, organizing, and maintaining the security policies required for SOC 2 compliance. It addresses which policies are required versus recommended, how to structure policy documents for auditor review, common policy gaps that trigger findings, version control and approval workflows, and how to write policies that employees actually follow. The target audience is compliance managers and security leads building the policy library that underpins their SOC 2 program.

For a complete SOC 2 preparation framework, see the SOC 2 readiness playbook. For evidence collection guidance, see the evidence collection guide.

Required SOC 2 Policies

Core Policy Library

Policy	TSC Category	What It Covers	Required?
Information Security Policy	CC1, CC2	Overall security program scope, objectives, governance, and management commitment	Required
Access Control Policy	CC5, CC6	User provisioning, authentication, authorization, access reviews, deprovisioning, MFA	Required
Change Management Policy	CC8	Change authorization, testing, deployment, code review, emergency changes, rollback	Required
Incident Response Policy	CC7	Incident detection, classification, response, communication, post-incident review	Required
Risk Assessment Policy	CC3	Risk identification, evaluation, treatment, risk register maintenance, review cadence	Required
Data Classification and Handling Policy	CC6, C1	Data categories, handling requirements, encryption, storage, transmission, disposal	Required
Acceptable Use Policy	CC1, CC6	Employee responsibilities for technology use, prohibited activities, security expectations	Required
Vendor Management Policy	CC9	Vendor evaluation, risk assessment, contractual requirements, monitoring, review cadence	Required
Business Continuity and Disaster Recovery Policy	CC7, CC9, A1	BCP scope, recovery priorities, DR procedures, testing requirements, communication	Required
Human Resources Security Policy	CC1	Background checks, onboarding, training, termination procedures, security responsibilities	Required

Supplementary Policies (Recommended)

Policy	When to Include
Encryption Policy	When data encryption controls warrant standalone documentation (often included in Data Classification)
Password Policy	When authentication requirements warrant standalone documentation (often included in Access Control)
Physical Security Policy	When the organization operates physical facilities requiring documented access controls
Privacy Policy	When pursuing the Privacy Trust Service Criterion
Patch Management Policy	When patch management processes are complex enough for standalone documentation
Logging and Monitoring Policy	When monitoring requirements warrant standalone documentation (often included in Incident Response)

Policy Document Structure

Standard Policy Format

Every policy document should follow a consistent structure that auditors can navigate efficiently:

Section	Content	Purpose
Header	Policy name, version number, effective date, next review date, owner, approver	Identifies the document and tracks version history
Purpose	One to two sentences explaining why the policy exists	Establishes context for the reader
Scope	Who and what the policy applies to	Defines applicability boundaries
Definitions	Key terms used in the policy	Ensures consistent interpretation
Policy statements	The actual rules, requirements, and expectations	The core of the document
Roles and responsibilities	Who is responsible for what	Clarifies accountability
Compliance	Consequences of non-compliance; exception process	Establishes enforcement
Related documents	References to related policies, procedures, or standards	Links to supporting documentation
Revision history	Table showing version changes, dates, and approvers	Demonstrates governance and maintenance

Writing Style Guidelines

Principle	Guidance	Example
Use clear, direct language	Avoid jargon, legalese, and ambiguous terms	"All employees must complete security training within 30 days of hire" (not "Personnel shall undertake appropriate awareness activities")
Be specific about requirements	State exactly what is required, by whom, and when	"Access reviews are conducted quarterly by system owners" (not "Access is reviewed periodically")
Match policy to practice	Document what you actually do, not what you aspire to do	If you conduct access reviews quarterly, write "quarterly" — not "monthly"
Use consistent terminology	Define terms and use them consistently across all policies	If you say "employees" in one policy, do not switch to "personnel" or "staff" in another
Include measurable criteria	Quantify requirements where possible	"Logs are retained for 365 days" (not "Logs are retained for an appropriate period")

Writing Each Core Policy

Information Security Policy

This is your master policy — it establishes the security program's scope, governance structure, and management commitment. It is the document auditors review first.

Key sections to include:

• Security program objectives and scope
• Management commitment to information security (signed by CEO or CTO)
• Governance structure (who oversees the security program)
• Policy framework overview (how policies are organized and maintained)
• Employee responsibilities
• Regulatory and compliance obligations
• Policy review and update cadence

Common gaps: Missing management signature or approval date; no review cadence defined; scope does not cover all in-scope systems.

Access Control Policy

Access management produces the most SOC 2 audit findings. Your access control policy must be specific enough that the auditor can verify every access management control against the documented requirements.

Key sections to include:

• User provisioning process (how access is granted)
• Role-based access control framework
• Authentication requirements (MFA enforcement, password complexity)
• Privileged access management (admin accounts, elevated permissions)
• Access review process (frequency, methodology, documentation)
• Deprovisioning process (timeline, systems covered, verification)
• Remote access controls
• Third-party access management

Common gaps: No specific deprovisioning timeline stated; access review frequency not defined; MFA requirements not specified for all access types; no privileged access management section.

Change Management Policy

Key sections to include:

• Change request and approval process
• Change categories (standard, emergency, maintenance)
• Code review requirements (who reviews, minimum reviewers, approval requirements)
• Testing requirements (staging environment, regression testing)
• Deployment procedures (deployment windows, rollback procedures)
• Emergency change procedures (expedited process with post-implementation review)
• Change documentation requirements

Common gaps: Emergency change procedure not defined; no rollback requirement stated; code review requirements not specific (e.g., number of required approvals not stated).

Incident Response Policy

Key sections to include:

• Incident classification framework (severity levels with definitions)
• Detection and reporting procedures
• Response team roles and responsibilities
• Escalation procedures by severity level
• Communication templates (internal notification, customer notification, regulatory notification)
• Evidence preservation requirements
• Post-incident review process
• Breach notification timelines (contractual and regulatory)

Common gaps: No severity classification defined; communication templates missing; no post-incident review requirement; breach notification timelines not aligned with contractual obligations.

Risk Assessment Policy

Key sections to include:

• Risk assessment methodology (qualitative, quantitative, or hybrid)
• Risk assessment scope and frequency (at minimum, annually)
• Risk identification approach
• Risk evaluation criteria (likelihood and impact scales)
• Risk treatment options (mitigate, accept, transfer, avoid)
• Risk register maintenance requirements
• Risk review and monitoring cadence
• Change-triggered risk reassessment requirements

Common gaps: No defined methodology; no frequency specified; no change-triggered reassessment requirement; risk acceptance process not documented.

Policy Approval and Distribution Workflow

Approval Process

Step	Action	Timeline
1	Policy author drafts or updates policy	Varies by policy
2	Compliance lead reviews for SOC 2 alignment	2-3 business days
3	Legal review (if applicable — data handling, privacy, employment policies)	3-5 business days
4	Management approval (CEO, CTO, or designated security executive)	2-5 business days
5	Version update and effective date recorded	Same day as approval
6	Distribution to all employees	Within one week of approval
7	Acknowledgment tracking begins	Ongoing until 100%

What Auditors Verify

Verification Point	What the Auditor Checks
Approval	Each policy has documented management approval with name and date
Currency	Policies have been reviewed within the last twelve months
Distribution	All policies have been distributed to all in-scope employees
Acknowledgment	All employees have acknowledged receipt and understanding of each policy
Accuracy	Policy content reflects actual organizational practices (verified during interviews)

Common Approval Failures

Failure	How to Avoid
Policies approved but no approval date recorded	Include approval signature block with date in every policy document
Policies not reviewed within twelve months	Set calendar reminders for annual review; track review dates in your GRC platform
Policies distributed but not acknowledged	Use your GRC platform's acknowledgment tracking; follow up with employees who have not acknowledged
Approval by wrong person	Define who has policy approval authority; typically CEO, CTO, or VP of Engineering

Version Control

Version Control Requirements

Requirement	Implementation
Unique version numbers	Use semantic versioning (1.0, 1.1, 2.0) or date-based versioning (2026-02-01)
Revision history table	Include a table in each policy showing version, date, author, and summary of changes
Previous version retention	Retain previous versions for auditor reference (GRC platforms handle this automatically)
Change justification	Document why each revision was made

Revision History Example

Version	Date	Author	Changes
1.0	2025-03-15	Jane Smith	Initial policy creation
1.1	2025-06-22	Jane Smith	Added MFA requirements for API access
2.0	2026-01-10	John Doe	Annual review; updated incident response timelines; added cloud access section

Common Policy Gaps That Trigger Audit Findings

Gap	Finding Severity	How to Avoid
Policy says "monthly access reviews" but reviews are done quarterly	Medium-High	Write policies that match your actual cadence; update policy before changing practice
Policy requires MFA but does not specify which access types	Medium	Specify: all production systems, cloud consoles, code repositories, and administrative tools
No emergency change procedure documented	Medium	Include emergency change section with expedited approval, documentation requirements, and post-implementation review
Policy not approved or approval date missing	Medium	Implement formal approval workflow with documented signatures and dates
Policy not reviewed within twelve months	Medium	Schedule annual reviews with calendar reminders; GRC platforms can automate review reminders
Employees acknowledged policies but were not given time to read them	Low (but risky)	Allow adequate review time before requiring acknowledgment; consider policy awareness sessions
Deprovisioning timeline not specified	High	State specific timeline: "Access is revoked within 24 hours of termination notification"
Password requirements do not match identity provider configuration	Medium	Align policy with actual IdP configuration; update both simultaneously when changes occur

Writing Policies Employees Actually Follow

The Readability Problem

Most SOC 2 policy templates are written for auditors, not employees. They use compliance jargon, legal language, and exhaustive detail that employees sign without reading. This creates a gap between documented policy and actual practice — the gap auditors identify during interviews and control testing.

Best Practices for Readable Policies

Practice	Implementation
Keep policies under ten pages	Separate detailed procedures into separate procedure documents; keep the policy focused on requirements
Use plain language	Write at an eighth-grade reading level; avoid jargon and acronyms without definitions
Include practical examples	Show employees what compliance looks like in their daily work
Create policy summaries	One-page summary documents for each policy highlighting key requirements employees need to know
Conduct policy awareness sessions	Brief team meetings explaining key policies when first distributed and during annual reviews
Test comprehension	During onboarding, ask employees about key policy requirements rather than just requiring a signature

Policy vs Procedure

Document Type	Purpose	Audience	Detail Level
Policy	States what must be done and why	All employees	High-level requirements and expectations
Procedure	States how to do it step by step	Specific roles and teams	Detailed implementation steps
Standard	States specific technical requirements	Engineering and IT	Technical specifications (e.g., encryption algorithms, password length)

Keep policies focused on requirements and expectations. Move step-by-step instructions to separate procedure documents. This keeps policies readable while maintaining the technical detail auditors need in supporting documentation.

Using GRC Platforms for Policy Management

GRC platforms like Vanta, Drata, Secureframe, and Sprinto provide built-in policy management capabilities:

Feature	What It Does
Template library	Pre-written SOC 2 policy templates covering all required policies
Customization editor	In-platform text editing for policy customization
Approval workflow	Route policies for management approval with tracked signatures
Distribution	Automated email distribution to all employees
Acknowledgment tracking	Track which employees have acknowledged each policy; send reminders
Version control	Automatic version tracking with revision history
Review reminders	Automated alerts when policies are due for annual review

For platform-specific implementation, see the Vanta implementation playbook and Secureframe implementation guide.

Key Takeaways

• We consistently see ten core policies required for SOC 2: Information Security, Access Control, Change Management, Incident Response, Risk Assessment, Data Classification, Acceptable Use, Vendor Management, Business Continuity/DR, and HR Security
• What we emphasize to every client: policies must match actual practice — auditors verify this during interviews, and the mismatch is the number one source of findings we see
• Every policy needs documented management approval with a date, annual review evidence, distribution to all employees, and 100% acknowledgment
• The most common policy findings we help clients remediate include: missing approval dates, policies not reviewed within twelve months, deprovisioning timelines not specified, and emergency change procedures not documented
• What we recommend for structure: use a consistent document format across all policies — header, purpose, scope, definitions, policy statements, roles, compliance, related documents, revision history
• Write policies in plain language at an eighth-grade reading level — in our experience, policies that employees cannot understand are policies employees do not follow
• We advise separating policies (what and why) from procedures (how) — keep policies focused on requirements
• GRC platforms provide policy templates, approval workflows, distribution, and acknowledgment tracking — we recommend using these features to automate the administrative burden
• Conduct policy awareness sessions so employees understand key requirements rather than simply signing acknowledgments

Frequently Asked Questions

Can I use policy templates directly from my GRC platform without customization?

What we tell clients is: absolutely not. Auditors verify that policies reflect your actual organizational practices — not generic templates. Using uncustomized templates creates two risks: (1) the policy states requirements you do not actually follow, creating a policy-practice gap the auditor will identify; (2) the policy omits organization-specific details that demonstrate your control environment is tailored to your operations. We always recommend customizing every template to reflect your tools, team structure, processes, and specific requirements.

How often do policies need to be reviewed?

Based on what we see in audits, annually at minimum. Auditors check whether policies have been reviewed within the last twelve months. We recommend setting calendar reminders or using your GRC platform's review scheduling feature to trigger annual reviews. Additionally, we advise reviewing policies when significant changes occur — organizational restructuring, infrastructure migration, tool changes, or regulatory updates that affect policy content.

What happens if a policy does not match our actual practice?

What we tell clients is that the auditor will note a discrepancy between documented policy and observed practice. Depending on severity, this may result in an exception (if the actual practice is weaker than the policy states) or an observation. The remediation is straightforward: update the policy to match your actual practice, or change your practice to match the policy. We always recommend aligning policy and practice before the audit observation period begins.

Do contractors and temporary employees need to acknowledge policies?

Based on what we see, yes — without exception. Any individual with access to in-scope systems should acknowledge relevant security policies. This includes full-time employees, part-time employees, contractors, temporary staff, and consultants with system access. Your GRC platform should track acknowledgment for all personnel categories.

How detailed should policies be?

What we recommend is: detailed enough for the auditor to understand your requirements and verify compliance, but not so detailed that every minor process change requires a policy update. State requirements and expectations in the policy; move step-by-step implementation details to separate procedure documents. This approach keeps policies stable (annual review is sufficient) while allowing procedures to be updated more frequently as operational details change.