How SOC 2 audits treat your print infrastructure

SOC 2 is the System and Organization Controls 2 reporting framework administered by the AICPA in the United States but widely accepted internationally. The framework evaluates a service organisation's controls relevant to security, availability, processing integrity, confidentiality, and privacy. Office MFPs fall within SOC 2 scope when the service organisation handles customer data through them, which most do indirectly through scan, print, and copy workflows. The piece below covers how SOC 2 audits actually look at print infrastructure, which trust services criteria apply most directly, and how to prepare an MFP fleet for inclusion in the SOC 2 control environment.

SOC 2 in plain language

SOC 2 produces a report that a service organisation can share with customers as evidence of its security and operational controls. The report covers five trust services criteria (TSC), with security mandatory and the other four optional based on what the organisation chooses to include in scope.

Customers increasingly request SOC 2 reports before engaging service providers, particularly in technology, finance, and healthcare adjacent industries. Office MFPs appear in the report as part of the service organisation's information technology environment.

The five trust services criteria

Security

Mandatory. Protection against unauthorised access.

Availability

Optional. Systems remain available for operation and use.

Processing integrity

Optional. Processing is complete, valid, accurate, and authorised.

Confidentiality

Optional. Confidential information is protected.

Privacy

Optional. Personal information handling.

The trust services criteria most relevant to office MFPs

Security is mandatory and applies directly to office MFPs as part of the information technology environment. Confidentiality applies when the MFPs handle confidential customer information, which they typically do. Privacy applies when the MFPs process personal information, also common. Availability matters less for office MFPs since occasional unavailability does not affect customer facing services in most service organisations. Processing integrity rarely applies to MFPs since they do not process transactions in the auditable sense.

Most SOC 2 reports that include MFPs cover the security and confidentiality criteria. The two together produce the strongest position for service organisations whose customers care about how the office handles their data through routine workflows.

The common criteria that apply directly to MFPs

CC6.1

Logical and physical access controls

The organisation implements logical and physical access controls to protect information assets from security events. Office MFPs require both physical placement controls and logical authentication controls.

Auditor will examine. User authentication configuration on each MFP, location of devices, secure print release, USB port disabling where appropriate.
CC6.2

Prior to issuing system credentials

Prior to issuing system credentials, the organisation identifies and registers users. The control applies to how MFP user accounts get created and tied to identities.

Auditor will examine. The integration between the MFP user directory and the broader identity directory. The procedures for granting and removing MFP access.
CC6.3

Authorised personnel access

The organisation authorises, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consideration to the concepts of least privilege and segregation of duties. The control applies to permission management on MFPs.

Auditor will examine. The mapping between user roles and MFP permissions. Whether sensitive operations require additional authorisation.
CC6.6

Restrict transmission of information

The organisation implements logical access security measures to protect against threats from sources outside its system boundaries. Transmission of MFP data needs encryption.

Auditor will examine. TLS encryption on print traffic. Encrypted protocols for scan to folder and scan to email.
CC6.7

Restrict access through configuration management

The organisation restricts the transmission, movement, and removal of information to authorised internal and external users and processes, and protects it during transmission, movement, or removal. The control applies to how data leaves the MFP, including scan destinations and decommissioning data wipe.

Auditor will examine. Scan destination configuration, decommissioning procedures, evidence of completed data wipes for retired devices.
CC7.1

Detection of security events

The organisation uses detection and monitoring procedures to identify changes to configurations that result in the introduction of new vulnerabilities, and susceptibilities to newly discovered vulnerabilities. The control applies to MFP configuration monitoring and vulnerability management.

Auditor will examine. The configuration baseline for MFPs, the audit procedure for detecting drift, the firmware patching routine.
CC7.2

Anomaly detection

The organisation monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the organisation's ability to meet its objectives. MFP audit logs support this control.

Auditor will examine. MFP audit logging configuration, log export to central analysis, evidence of log review and follow up.
CC8.1

Change management

The organisation authorises, designs, develops, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives. The control applies to MFP firmware updates and configuration changes.

Auditor will examine. The firmware patching procedure, the change documentation, the testing approach before applying updates.

The confidentiality criteria for MFPs

C1.1

Identifies and maintains confidential information

The organisation identifies the confidential information that it has committed to maintain. The classification of information processed through MFPs feeds into this control.

Auditor will examine. The information classification policy, how MFP processed data is classified, the retention periods applied to each classification.
C1.2

Disposes of confidential information

The organisation disposes of confidential information to meet its objectives. The MFP decommissioning procedure addresses this control directly.

Auditor will examine. The decommissioning procedure, wipe certificates for retired devices, the records of processing covering retention and deletion.

SOC 2 Type 1 versus Type 2

The two SOC 2 report types

SOC 2 Type 1 reports on the design of controls at a specific point in time. The auditor verifies that the controls described in the system description are designed to meet the criteria. The report supports an initial position but does not demonstrate sustained operation.

SOC 2 Type 2 reports on the operating effectiveness of controls over a period, typically six to twelve months. The auditor samples evidence from across the period to confirm the controls operated as designed. The report carries more weight with customers but requires the controls to be operating consistently before the audit period begins.

What MFP evidence the auditor typically requests

For Type 1 audits, the auditor reviews the documented controls and the current state of each MFP. The evidence is the configuration screenshots, the inventory record, the policies and procedures, and similar point in time documents. The auditor then walks through one or two devices to confirm the documented state matches reality.

For Type 2 audits, the auditor samples evidence from across the audit period. Typical requests include firmware update tickets from the past year, change management records for any MFP configuration changes, monthly log review summaries, quarterly access reviews, and decommissioning certificates for any retired devices. The evidence demonstrates that the controls operated consistently rather than just being in place at a single point.

Preparing the MFP fleet for SOC 2

Service organisations approaching SOC 2 for the first time typically need three to six months to prepare the MFP fleet. The preparation covers documenting the current state, addressing any control gaps, establishing the quarterly review routine, and accumulating evidence for the planned audit period. Type 2 audits then need an additional six to twelve months of operating evidence before the audit can occur.

Organisations that have already implemented the ISO 27001 controls covered in the preceding piece find SOC 2 readiness substantially easier. The two frameworks share many underlying controls, with the SOC 2 evidence often being a different presentation of the same operational data the ISO 27001 ISMS already produces.

The cost of MFP related SOC 2 work

The MFP specific portion of SOC 2 preparation typically represents 5 to 10 percent of the total SOC 2 work. The relatively small portion reflects the maturity of office MFP security controls as standard practice rather than novel implementation. Service organisations that have applied the broader security cluster covered in this pillar usually find the SOC 2 MFP requirements satisfied through controls they already operate.

The ongoing maintenance for MFP related SOC 2 evidence takes 8 to 12 hours per year of focused attention, mostly in the form of the quarterly review documentation and the annual audit preparation. The investment supports the broader organisational benefit of SOC 2 certification, which has become a standard expectation in many enterprise procurement processes.

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