SOC 2 to HIPAA Security Rule crosswalk
29 control objectives in SOC 2 Trust Services Criteria are mapped here to HIPAA Security Rule and Breach Notification Rule. 5 of them have no direct HIPAA Security Rule requirement, which is marked in the table. Each row is one shared objective, with the requirement ids on both sides.
| Control objective | SOC 2 | HIPAA Security Rule |
|---|---|---|
| Security governance and policies | CC1.1Demonstrates commitment to integrity and ethical valuesCC1.2Board exercises oversight responsibilityCC5.3Deploys control activities through policies and procedures | 164.308(a)(1)(i)Security management process164.316(a)Policies and procedures |
| Security roles and accountability | CC1.3Establishes structure, authority and responsibilityCC1.5Enforces accountability | 164.308(a)(2)Assigned security responsibility |
| Risk assessment and treatment | CC3.1Specifies suitable objectivesCC3.2Identifies and analyzes riskCC3.3Considers potential for fraudCC3.4Identifies and assesses significant changes | 164.308(a)(1)(ii)(A)Risk analysis164.308(a)(1)(ii)(B)Risk management |
| Asset and system inventory | CC6.1Logical access security (inventory of information assets is a point of focus) | 164.310(d)(2)(iii)Accountability (record of hardware and media movements) |
| Data classification and handling | C1.1Identifies and maintains confidential information | 164.308(a)(1)(ii)(A)Risk analysis (requires identifying where ePHI lives) |
| Access provisioning, review and removal | CC6.2Registers and authorizes new users prior to issuing credentialsCC6.3Authorizes, modifies or removes access based on roles | 164.308(a)(3)Workforce security (authorization, supervision, termination)164.308(a)(4)Information access management |
| Least privilege and privileged access | CC6.3Role-based access and least privilege | 164.312(a)(1)Access control164.308(a)(4)Information access management |
| Authentication, unique IDs and multi-factor authentication | CC6.1Logical access security software, infrastructure and architectures | 164.312(d)Person or entity authentication164.312(a)(2)(i)Unique user identification |
| Encryption at rest and key management | CC6.1Logical access security (encryption of data at rest) | 164.312(a)(2)(iv)Encryption and decryption (addressable) |
| Encryption in transit | CC6.7Restricts transmission, movement and removal of information | 164.312(e)(1)Transmission security |
| Network security and segmentation | CC6.6Implements logical access security measures against threats from outside system boundaries | no direct requirement |
| Secure configuration and hardening | CC7.1Uses detection and monitoring procedures to identify changes to configurations | no direct requirement |
| Vulnerability scanning and patching | CC7.1Detection and monitoring procedures identify vulnerabilities | 164.308(a)(8)Evaluation (periodic technical evaluation) |
| Penetration testing and independent assessment | CC4.1Selects, develops and performs ongoing and/or separate evaluationsCC7.1Detection and monitoring procedures | 164.308(a)(8)Evaluation |
| Logging, log review and monitoring | CC7.2Monitors system components for anomalies indicative of malicious acts, natural disasters and errors | 164.312(b)Audit controls164.308(a)(1)(ii)(D)Information system activity review |
| Intrusion detection and integrity monitoring | CC7.2Monitors system components for anomaliesCC6.8Prevents or detects unauthorized or malicious software | 164.312(c)(1)Integrity |
| Malware protection | CC6.8Implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software | 164.308(a)(5)(ii)(B)Protection from malicious software |
| Incident response and breach notification | CC7.3Evaluates security events to determine whether they are incidentsCC7.4Responds to identified security incidentsCC7.5Identifies, develops and implements activities to recover from incidents | 164.308(a)(6)Security incident procedures164.404Notification to individuals (Breach Notification Rule) |
| Change management | CC8.1Authorizes, designs, develops, configures, documents, tests, approves and implements changes | no direct requirement |
| Secure software development | CC8.1Changes are developed, tested and approved | no direct requirement |
| Third-party and vendor risk management | CC9.2Assesses and manages risks associated with vendors and business partners | 164.308(b)(1)Business associate contracts and other arrangements164.314(a)Business associate contracts or other arrangements |
| Business continuity and disaster recovery | CC9.1Identifies, selects and develops risk mitigation activities for business disruptionsA1.2Environmental protections, software, data backup processes and recovery infrastructureA1.3Tests recovery plan procedures | 164.308(a)(7)Contingency plan |
| Backup and redundancy | A1.2Data backup processes and recovery infrastructure | 164.308(a)(7)(ii)(A)Data backup plan164.308(a)(7)(ii)(B)Disaster recovery plan |
| Capacity and availability management | A1.1Maintains, monitors and evaluates current processing capacity | no direct requirement |
| Security awareness and training | CC1.4Demonstrates commitment to attract, develop and retain competent individualsCC2.2Internally communicates information necessary to support internal control | 164.308(a)(5)Security awareness and training |
| Personnel screening, terms and sanctions | CC1.4Hiring and competence practicesCC6.3Removes access on termination | 164.308(a)(3)(ii)(B)Workforce clearance procedure164.308(a)(3)(ii)(C)Termination procedures164.308(a)(1)(ii)(C)Sanction policy |
| Physical access and facility security | CC6.4Restricts physical access to facilities and protected information assets | 164.310(a)Facility access controls |
| Data retention, media handling and secure disposal | CC6.5Discontinues logical and physical protections over assets only after the ability to read or recover data is diminishedC1.2Disposes of confidential information | 164.310(d)(2)(i)Disposal164.310(d)(2)(ii)Media re-use |
| Ongoing control monitoring and internal audit | CC4.1Selects, develops and performs ongoing and/or separate evaluationsCC4.2Evaluates and communicates internal control deficiencies | 164.308(a)(8)Evaluation |
Scope: Security (CC series), Availability (A1) and Confidentiality (C1). Processing Integrity and Privacy are not covered in this dataset version. Citations are to 45 CFR 164. 'Addressable' vs 'required' implementation specifications are not distinguished here. Several themes have no direct HIPAA citation. A mapping means the requirements address the same objective. It does not mean satisfying one satisfies the other, because scope, frequency and evidence rules differ.