SOC 2 CC2.3: Managing External Communication About Internal Controls
External communication about internal control matters isn't optional—it's a SOC 2 requirement. CC2.3 mandates that your organization formally communicate with third parties, regulators, and service providers about control-relevant issues. This control ensures nothing slips through the cracks when control deficiencies or changes affect how your systems operate.
What this means
CC2.3 requires your organization to establish and maintain processes for communicating with external parties—including customers, regulators, auditors, and service providers—regarding matters that affect the design, operation, or effectiveness of your internal controls. This includes reporting control failures, policy changes, security incidents, and compliance updates. The control ensures transparency and accountability while keeping relevant stakeholders informed of control-related developments that could impact their reliance on your services.
How to comply
- 1.Map all external parties who have a legitimate need to know about control matters (customers, vendors, regulators, audit firms, insurers)
- 2.Document your communication policy specifying what types of control-related events trigger external notification
- 3.Define communication timelines and escalation paths for control failures, changes, and incidents
- 4.Implement notification procedures for each category: security breaches, control deficiencies, system changes, compliance findings
- 5.Create communication templates that clearly explain control impacts and required actions
- 6.Establish approval workflows ensuring management reviews control communications before sending
- 7.Log all external communications about control matters with date, recipient, content, and response
- 8.Review and test communication procedures at least annually or when control scope changes
Evidence auditors look for
- Communication policy document defining external parties and notification requirements
- Breach notification logs showing dates, recipients, and communication content
- Control change bulletins sent to customers explaining system modifications
- Service provider incident reports and follow-up communications
- Audit finding communications to relevant stakeholders
- Email records of regulatory notifications about control deficiencies
- Internal escalation logs triggering external communication decisions
- Approval sign-offs on control-related communications before distribution
- Customer acknowledgment forms confirming receipt of control updates
- Third-party confirmation records showing external parties received notifications
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
GRCWatch automates external communication logging and approval workflows, ensuring every control-related notification is documented, timestamped, and properly escalated—eliminating manual tracking and audit gaps in CC2.3 compliance.
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