C1.1 Identifying and maintaining confidential information
Confidential information is identified and kept in line with the organisation's confidentiality objectives. Points of focus: procedures define confidential information and identify and designate it when received or created, and set how long it is kept; it is protected from erasure or destruction during that period; and, added in 2022, it is kept no longer than the identified purpose needs unless a law or regulation requires otherwise.
Source: SOC 2 (2017 Trust Services Criteria), C1.1. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open SOC 2 (2017 Trust Services Criteria) in the compliance library.
These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Evidence of deletion or review when confidential information passes its retention period · Data governance / DLP tooling
governing documentDocuments that govern the control
- Data classification policy defining confidential information · Policy repository / GRC workspace
- Data inventory tagging confidential data and its retention period · Policy repository / GRC workspace
- Retention schedule and controls preventing premature deletion · Policy repository / GRC workspace
First move
Common gaps auditors find
- Confidential customer data not identified in any inventory
- No defined retention period for confidential information
- Confidential data deletable by anyone with general access
- Confidential data kept indefinitely after the purpose ended
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetA1.3 Testing recovery plan procedures · C1.2 Disposing of confidential information