For anyone unaware, a SOC3 is just a SOC2 with the audit details removed - it includes a high level statement from the company (Apple) and from the auditor (EY), that's it.
Also Apple certainly does invest heavily in security and privacy but SOC2's are so commoditized that it's like saying "look I can afford 50k", it's not particularly interesting
Importantly, anyone can get SOC2 (Type 1) by claiming some controls they figure they'll look at themselves.
SOC2 (Type 2) in theory requires an audit that you're actually doing what you said you'd do in (Type 1).
Both may also allow general lag time.
Note that firms decide on their own which controls to include, meaning, they get to decide to include or exclude various controls, the audit is on only the ones they picked. Pick basic controls, it's cheaper to pass easily, and now you have a logo.
This means SOC2s of either type cannot be compared to one another (and SOC2 Type 1 are roughly logo-ware).
SOC3 is, roughly, SOC2 redacted.
Recap:
SOC2 Type 1 is a firm picking some controls to say they'll do them, SOC2 Type 2 is roughly a firm having someone look at whether they're doing that (warning, screenshots might suffice, audit verification is probably not what you think), and SOC3 is public or non-confidential water down of that, typically without findings.
The only thing that matters is what controls, specifically, they're actually audited on. So ideally you want to know what the controls they picked are, and that a SOC2 Type 2 was audited on those.
Btw, keep in mind that "end to end encryption" means "https" and most controls have similarly basic ways of achieving them. It's difficult to fail SOC2 Type 2 core controls if you know "don't be useless" is how you pass them.
Also, it's not $50K even through the big five DIY SOC2 Type 2 shops. You can use the same ones trillion dollar firms use, by signing up online, and you'll be surprised how inexpensive relative to the cost of failing to let a business check that box in their procurement process.
I think both of you meant “Delve”, not “Deel”. Deel is a pretty successful HR startup that’s still growing at a good rate and AFAIK free of major scandals.
Again, Deel is HR, not SOC2. Delve was the SOC2 company described in the article linked above.
As a German I remember that they were banned from doing certain audits in Germany until earlier this year due to their involvement in the wirecard scandal. So at least my personal believe that their audits are done rigorously is nonexistent.
Not really. The more expensive the auditor, the more they'll work with you to craft something that will avoid exceptions. There's no real "rigor" involved in SOC2! The "audit" here is in audit in the accounting sense: "do your records square up?". SOC2 auditors are generally not technical people.
> SOC2 (Type 2) in theory requires an audit that you're actually doing what you said you'd do in (Type 1).
Even with an external audit - think of how many projects and repositories and servers and libraries and legacy systems Apple, a 50-year-old company with 166,000 employees, could have.
Then think about how much inspection is involved in a $50,000 audit. I doubt you get more than one inspector working full time for a year. In which case they've got 45 seconds of to audit each employee's entire work output. And places like EY will bill some people out at $700/hour, so it could be an order of magnitude less than that.
So this isn't some fine-toothed-comb forensic investigation or adversarial penetration test.
Literally any firm can get a SOC2 Type 1, because there's no lookback to it; the Type 1 is a pinky swear.
In practice, if you're careful about how you do your Type 1, the Type 2 is almost as trivial. Your HR/bizops practice is much more likely to screw up and cause exceptions than anything you do in IT or engineering.
From my 8 years of working SOC2 Type 2 audits done by PwC for a large PaaS Cloud with a worldwide presence (not the big 3) saying Type 2 is almost as trivial as type 1 is absolutely false. This might be true for someone running their own low volume SaaS in one region but for someone the size of Apple they are investing a lot of resource to stay on top of the controls, especially patching and permissions. If you've invested heavily in homogenization and automation your less likely to fail and the audits will be simpler. Even with significant investment I expect there are many aging corners in any "cloud" that make audits subject to failure and require a lot of work to avoid qualifying exceptions.
I'm not going to, like, whip out my resume here, but I am going to confidently assert that if you structure your Type 1 carefully, you can trivialize your Type 2, and as someone currently operating a globally deployed public cloud I can tell you right now that SOC2 doesn't really touch on anything interesting in our engineering.
I wrote an article about this, and I think it's the Correct advice for virtually every startup thinking about SOC2:
A few years before that, I wrote an article about what we learned from the consulting practice we ran building SOC2-supporting security programs for startups:
I've had the experience, many times, of offering this advice in some forum and having someone try to rebut it, claiming that SOC2 is difficult, or that real customers will pick a SOC2 attestation apart with a fine-toothed comb looking for shortcuts you took, or that they built their whole security practice around SOC2. I can go all 12 rounds with someone on any of those points, but I think you can get most of my take from those two posts.
It doesn't look like fly.io publicly disclose who there auditor is so it is hard to judge that specific part of your experience. I'm not disagreeing with your perspective on startups. I'm saying that type 2 gets much harder when you are large. non-homogenous and lack sufficient automation and monitoring.
Well you "claiming controls" to an independent CPA auditor. If a licensed CPA helps you lie -- they might lose their license (and can even get to prison), just like a tax preparer CPA can.
(Specifically: the SOC3 is a public report; the SOC2 report generally isn't supposed to be handed out except to named clients under contract. You pay extra to get the auditors to give you a report you can just stick on a website.)
The details people gloss over when throwing SOC 2 or whatever other audit costs around are the complexity of the system being audited, the chosen criteria to audit (AICPA defines 5 families of criteria... Security is one, but you can optionally add Processing Integrity, Confidentiality, etc etc) and the reputation of the auditor.
A security-only audit for a small company with a narrow product focus can indeed be very inexpensive. A full SOC 2 examination for a large organization with a mix of legacy and modern systems by a name-recognizable public accounting firm can be many hundreds of thousands of dollars, or more if you need a Big 4 firm.
In my opinion, there's not much value to the "cheap" audits... If you're doing enterprise sales to a certain kind of client, your partners who demand an audit are going to want a reputable auditor or they're just going to put you through their own in-depth procurement due diligence regardless. The segment of the industry where a SOC 2 attestation is mandatory to participate but where any random auditor will do feels pretty narrow.
Unless you have a very good reason (I compare notes with people at dozens of firms and have never heard one), the only criteria you ever want to get SOC2'd on is Security.
My experience is the opposite of yours: having a security SOC2 ends the vendorsec process it any enterprise buyer, and enterprise buyers virtually never read anything in the SOC2 other than a glance at the exceptions. A very large, very security-intensive vendor we have all heard of told me a story about a vendor they had that gave them several years of repeated Type 1 reports. Went fine.
I'll just cite my 30 years in IT/InfoSec. Believe it or not, I really don't give a damn. It's common knowledge int he field regardless of what your experience is.
I wouldn't put it the way they did but they're directionally sane about this. I would worry a lot more about someone repping their SOC2 as important or meaningful than I would worry about someone who was cynical about SOC2.
(I don't mean Apple; Apple spends more on security than almost any firm in the world.)
My experience with pen tests that you put above or on par with SOC2 Type 2 security mirrors the discussion here. It all comes down to the reputation of the firm doing the testing.
1. No, it does not require 50k, an auditor can cost way less (10k? maybe even less).
2. But the process of preparing for the audit will take a lot of work securing your systems (and increasing reliability and privacy as well), as long as you take it seriously. Of course you can lie to the auditor, but it's up on you. And auditor -- they might lose their CPA license and go to prison. Their job is to catch your lies.
Source -- went through it, and took it seriously. It really did increase our security stance, even though we thought we were good at it.
That auditors are responsible for catching the lies of an audited company on penalty of being suspended is a position that the big audit firms would not agree with. They might agree that they are responsible for ensuring the material accuracy of accounts if fraud occurs, but even here EY has disclaimed responsibility if the fraud were sufficiently complex [0]. Indeed auditors lobbied very hard against being mandated with a broader anti-fraud role [1].
Admittedly this is on the "real" audit side and not the advisory/consulting side, which would be the ones to handle SOC I imagine, but nonetheless a position I find a bit absurd.
> Admittedly this is on the "real" audit side and not the advisory/consulting side, which would be the ones to handle SOC I imagine, but nonetheless a position I find a bit absurd.
I mean, it's not like the supposed "Chinese wall" at the Big 4 has ever been accused of being "illusory" on multiple occasions.
I'm scared of companies where SOC2 auditors are driving their security improvements. It's a bit like letting my toddler drive how I stock my pantry: surely by the end the pantry will be more full, but not really in the way I want.
I co-ran a business with a significant SOC2 practice (we ran security programs for startups), and then oversaw Fly.io's SOC2 Type 2. The person you're responding to is more right than you are, and I would push back in a variety of ways on your point (2).
can someone correct me - so apple is using servers that are running a closed down version of iOS on what I would assume is apple silicone, probably excess chips or older chips for the iCloud Private Cloud ?
For anyone unaware, a SOC3 is just a SOC2 with the audit details removed - it includes a high level statement from the company (Apple) and from the auditor (EY), that's it.
Also Apple certainly does invest heavily in security and privacy but SOC2's are so commoditized that it's like saying "look I can afford 50k", it's not particularly interesting
Importantly, anyone can get SOC2 (Type 1) by claiming some controls they figure they'll look at themselves.
SOC2 (Type 2) in theory requires an audit that you're actually doing what you said you'd do in (Type 1).
Both may also allow general lag time.
Note that firms decide on their own which controls to include, meaning, they get to decide to include or exclude various controls, the audit is on only the ones they picked. Pick basic controls, it's cheaper to pass easily, and now you have a logo.
This means SOC2s of either type cannot be compared to one another (and SOC2 Type 1 are roughly logo-ware).
SOC3 is, roughly, SOC2 redacted.
Recap:
SOC2 Type 1 is a firm picking some controls to say they'll do them, SOC2 Type 2 is roughly a firm having someone look at whether they're doing that (warning, screenshots might suffice, audit verification is probably not what you think), and SOC3 is public or non-confidential water down of that, typically without findings.
The only thing that matters is what controls, specifically, they're actually audited on. So ideally you want to know what the controls they picked are, and that a SOC2 Type 2 was audited on those.
Btw, keep in mind that "end to end encryption" means "https" and most controls have similarly basic ways of achieving them. It's difficult to fail SOC2 Type 2 core controls if you know "don't be useless" is how you pass them.
Also, it's not $50K even through the big five DIY SOC2 Type 2 shops. You can use the same ones trillion dollar firms use, by signing up online, and you'll be surprised how inexpensive relative to the cost of failing to let a business check that box in their procurement process.
I think companies like Deel showed that SOC2 is more show than anything else.
For context, this is how easy it is to get a SOC2: https://deepdelver.substack.com/p/delve-fake-compliance-as-a...
Delve. Not Deel. Very different startups.
Hasn't Deel been run out of business though?
IME SOC2 is still quite involved for any company, especially smaller ones without specialized security personnel.
I think both of you meant “Delve”, not “Deel”. Deel is a pretty successful HR startup that’s still growing at a good rate and AFAIK free of major scandals.
Again, Deel is HR, not SOC2. Delve was the SOC2 company described in the article linked above.
Right, Delve was the company I was thinking of. Thanks for pointing that out.
Their website is still up, but I have a hunch you can find some other certificate mill that will give you a SOC2 certificate just as easily.
A SOC2's quality entirely depends on how much you trust the auditing firm.
Delve used an audit mill they paid to rubber-stamp the cookie-cutter and AI slop reports it authored. I hope it ends up in fraud charges.
But I wouldn't assume that's the case for all SOC2 reports. Any decent auditing firm should be far more rigorous.
These audits for Apple were done by EY.
As a German I remember that they were banned from doing certain audits in Germany until earlier this year due to their involvement in the wirecard scandal. So at least my personal believe that their audits are done rigorously is nonexistent.
https://edition.cnn.com/2023/04/03/business/wirecard-ey-ban-...
Not really. The more expensive the auditor, the more they'll work with you to craft something that will avoid exceptions. There's no real "rigor" involved in SOC2! The "audit" here is in audit in the accounting sense: "do your records square up?". SOC2 auditors are generally not technical people.
> SOC2 (Type 2) in theory requires an audit that you're actually doing what you said you'd do in (Type 1).
Even with an external audit - think of how many projects and repositories and servers and libraries and legacy systems Apple, a 50-year-old company with 166,000 employees, could have.
Then think about how much inspection is involved in a $50,000 audit. I doubt you get more than one inspector working full time for a year. In which case they've got 45 seconds of to audit each employee's entire work output. And places like EY will bill some people out at $700/hour, so it could be an order of magnitude less than that.
So this isn't some fine-toothed-comb forensic investigation or adversarial penetration test.
A $50k audit is going to be team of 2 CPAs collecting evidence for 2 weeks.
Literally any firm can get a SOC2 Type 1, because there's no lookback to it; the Type 1 is a pinky swear.
In practice, if you're careful about how you do your Type 1, the Type 2 is almost as trivial. Your HR/bizops practice is much more likely to screw up and cause exceptions than anything you do in IT or engineering.
From my 8 years of working SOC2 Type 2 audits done by PwC for a large PaaS Cloud with a worldwide presence (not the big 3) saying Type 2 is almost as trivial as type 1 is absolutely false. This might be true for someone running their own low volume SaaS in one region but for someone the size of Apple they are investing a lot of resource to stay on top of the controls, especially patching and permissions. If you've invested heavily in homogenization and automation your less likely to fail and the audits will be simpler. Even with significant investment I expect there are many aging corners in any "cloud" that make audits subject to failure and require a lot of work to avoid qualifying exceptions.
I'm not going to, like, whip out my resume here, but I am going to confidently assert that if you structure your Type 1 carefully, you can trivialize your Type 2, and as someone currently operating a globally deployed public cloud I can tell you right now that SOC2 doesn't really touch on anything interesting in our engineering.
I wrote an article about this, and I think it's the Correct advice for virtually every startup thinking about SOC2:
https://fly.io/blog/soc2-the-screenshots-will-continue-until...
A few years before that, I wrote an article about what we learned from the consulting practice we ran building SOC2-supporting security programs for startups:
https://www.latacora.com/blog/2020/03/12/soc2-starting-seven...
I've had the experience, many times, of offering this advice in some forum and having someone try to rebut it, claiming that SOC2 is difficult, or that real customers will pick a SOC2 attestation apart with a fine-toothed comb looking for shortcuts you took, or that they built their whole security practice around SOC2. I can go all 12 rounds with someone on any of those points, but I think you can get most of my take from those two posts.
It doesn't look like fly.io publicly disclose who there auditor is so it is hard to judge that specific part of your experience. I'm not disagreeing with your perspective on startups. I'm saying that type 2 gets much harder when you are large. non-homogenous and lack sufficient automation and monitoring.
Our auditor is Aprio.
Well you "claiming controls" to an independent CPA auditor. If a licensed CPA helps you lie -- they might lose their license (and can even get to prison), just like a tax preparer CPA can.
(Specifically: the SOC3 is a public report; the SOC2 report generally isn't supposed to be handed out except to named clients under contract. You pay extra to get the auditors to give you a report you can just stick on a website.)
Last I chatted with some friends who were going through their first SOC2, they quoted a much lower number.
The details people gloss over when throwing SOC 2 or whatever other audit costs around are the complexity of the system being audited, the chosen criteria to audit (AICPA defines 5 families of criteria... Security is one, but you can optionally add Processing Integrity, Confidentiality, etc etc) and the reputation of the auditor.
A security-only audit for a small company with a narrow product focus can indeed be very inexpensive. A full SOC 2 examination for a large organization with a mix of legacy and modern systems by a name-recognizable public accounting firm can be many hundreds of thousands of dollars, or more if you need a Big 4 firm.
In my opinion, there's not much value to the "cheap" audits... If you're doing enterprise sales to a certain kind of client, your partners who demand an audit are going to want a reputable auditor or they're just going to put you through their own in-depth procurement due diligence regardless. The segment of the industry where a SOC 2 attestation is mandatory to participate but where any random auditor will do feels pretty narrow.
Unless you have a very good reason (I compare notes with people at dozens of firms and have never heard one), the only criteria you ever want to get SOC2'd on is Security.
My experience is the opposite of yours: having a security SOC2 ends the vendorsec process it any enterprise buyer, and enterprise buyers virtually never read anything in the SOC2 other than a glance at the exceptions. A very large, very security-intensive vendor we have all heard of told me a story about a vendor they had that gave them several years of repeated Type 1 reports. Went fine.
You can get a SOC2 done for mid to mid-high thousands.
Everyone lies on SOC2. Auditors don't understand the technologies and just take peoples word for it. It's a shit practice
Citation needed. This is not my experience at all, after participating in such efforts at three different companies.
I'll just cite my 30 years in IT/InfoSec. Believe it or not, I really don't give a damn. It's common knowledge int he field regardless of what your experience is.
Can you name the names of SOC auditors that are rubber stamping?
Or point me to some public critiques within the industry?
Wasn’t that YC startup Delve doing exactly this?
https://www.iansresearch.com/resources/all-blogs/post/securi...
That I'm familiar with. Is it part of a trend or just one bad apple?
I wouldn't put it the way they did but they're directionally sane about this. I would worry a lot more about someone repping their SOC2 as important or meaningful than I would worry about someone who was cynical about SOC2.
(I don't mean Apple; Apple spends more on security than almost any firm in the world.)
https://fly.io/blog/soc2-the-screenshots-will-continue-until...
My experience with pen tests that you put above or on par with SOC2 Type 2 security mirrors the discussion here. It all comes down to the reputation of the firm doing the testing.
> "look I can afford 50k"
Oh no. Looks like you never went through SOC2.
1. No, it does not require 50k, an auditor can cost way less (10k? maybe even less).
2. But the process of preparing for the audit will take a lot of work securing your systems (and increasing reliability and privacy as well), as long as you take it seriously. Of course you can lie to the auditor, but it's up on you. And auditor -- they might lose their CPA license and go to prison. Their job is to catch your lies.
Source -- went through it, and took it seriously. It really did increase our security stance, even though we thought we were good at it.
That auditors are responsible for catching the lies of an audited company on penalty of being suspended is a position that the big audit firms would not agree with. They might agree that they are responsible for ensuring the material accuracy of accounts if fraud occurs, but even here EY has disclaimed responsibility if the fraud were sufficiently complex [0]. Indeed auditors lobbied very hard against being mandated with a broader anti-fraud role [1].
Admittedly this is on the "real" audit side and not the advisory/consulting side, which would be the ones to handle SOC I imagine, but nonetheless a position I find a bit absurd.
[0]: https://www.ft.com/content/a9deb987-df70-4a72-bd41-47ed8942e...? [1]: https://www.ft.com/content/c25de9fb-a808-4946-ade6-80d76a66a...
> Admittedly this is on the "real" audit side and not the advisory/consulting side, which would be the ones to handle SOC I imagine, but nonetheless a position I find a bit absurd.
I mean, it's not like the supposed "Chinese wall" at the Big 4 has ever been accused of being "illusory" on multiple occasions.
I'm scared of companies where SOC2 auditors are driving their security improvements. It's a bit like letting my toddler drive how I stock my pantry: surely by the end the pantry will be more full, but not really in the way I want.
I co-ran a business with a significant SOC2 practice (we ran security programs for startups), and then oversaw Fly.io's SOC2 Type 2. The person you're responding to is more right than you are, and I would push back in a variety of ways on your point (2).
can someone correct me - so apple is using servers that are running a closed down version of iOS on what I would assume is apple silicone, probably excess chips or older chips for the iCloud Private Cloud ?
I'm glad they're doing them.
Audits are decidedly imperfect, but on balance people tend to toe the line better on good practices when they know they're being audited.
the page keeps 301ing to the home page for me - could be a region issue
https://archive.ph/JYC9B
Same in Italy
Works for me on a major US cell network.
Every audit is a cooked book audit. At least every single one Ive been a part of. Check mark tests.
I thought they were working on M5 already? Why are they still auditing M3?
Thats the only Studio available