P3.2 Explicit consent before collecting information that requires it
Where information requires explicit consent, the need for consent and the consequences of withholding it are explained, and consent is obtained before collection. Points of focus: explicit consent is obtained directly for sensitive personal information unless law says otherwise; and documentation of that consent is retained in line with privacy objectives.
Source: SOC 2 (2017 Trust Services Criteria), P3.2. 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
- Retained consent records linked to data subjects · Data governance / DLP tooling
governing documentDocuments that govern the control
- Explicit consent wording and capture mechanism for sensitive data · Policy repository / GRC workspace
- Inventory of sensitive personal information categories · Policy repository / GRC workspace
First move
Common gaps auditors find
- Sensitive data collected before consent is captured
- Consent records not retained
- Sensitive categories not identified
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 sheetP3.1 Collecting personal information consistent with objectives · P4.1 Limiting use to identified purposes