Generative AI (Gen AI) has emerged as a transformative force. From streamlining operations to enhancing customer experiences, AI-powered solutions offer unprecedented opportunities for businesses of all sizes. However, these advancements also introduce new challenges—especially when it comes to cybersecurity. As companies embrace Gen AI, staying compliant with industry standards like SOC 2 is more critical than ever. In fact, Gen AI products are making it increasingly difficult to maintain a secure environment, which could significantly impact your business. This article explores how to integrate Gen AI into your SOC 2 compliance strategy, ensuring you stay ahead of the curve while mitigating risks.
The New Frontier of Cybersecurity Challenges
As Gen AI-driven products flood the market, they offer countless benefits but also expose companies to heightened security vulnerabilities. Gen AI solutions, while innovative, are often not fully mature when it comes to cybersecurity. These tools can unintentionally introduce security and privacy risks—such as unauthorized data use with respect to input and output data, security vulnerabilities and other compliance failures—that can compromise the security of your organization.
If Gen AI hasn’t yet played a role in your SOC 2 compliance review, it’s time to start integrating Gen AI products and services into your plan. Failing to address Gen AI’s impact could put your company’s data security and reputation at risk.
Incorporating Generative AI into Your SOC 2 Compliance Plan
Here are actionable steps to incorporate Gen AI into your SOC 2 plan:
Develop a Gen AI-Specific Use Policy: As with any new technology, your first step should be to establish a Gen AI usage policy. This policy should clearly outline how Gen AI products and services will be used within your company (with prohibited and accepted use cases), the risks associated with it, and the controls in place to mitigate those risks. Implementing periodic Gen AI use training programs are also a must to raise employee awareness.
Conduct Written AI Risk Assessments: Gen AI brings both known and unforeseen risks. A thorough, documented risk impact assessment should be conducted, focusing on areas like what data is being ingested by the Gen AI engine, whether the output is being monitored, whether use of Gen AI is creating data privacy or IP issues, and an in-depth review of the Gen AI system’s security integrity. This assessment will serve as the foundation for your Gen AI security controls and must be updated regularly as Gen AI technologies evolve.
Prepare for Gen AI Scrutiny in Audits: SOC 2 auditors are becoming increasingly focused on how companies manage new technologies, especially Gen AI. What might have been acceptable last year may no longer suffice as your company matures. For example, certain departments within your company may be using software with Gen AI capabilities that could be processing customer data or other confidential or sensitive data, so make sure you have reviewed all aspects of possible Gen AI use in your company. Auditors are expecting a more robust, in-depth review of all Gen AI-powered functionality within your company’s systems. These expectations will only intensify with Gen AI’s growing role in business processes.
Planning for the Future
When your company undergoes its next SOC 2 audit, auditors will likely hold you accountable for how you incorporate Gen AI into your compliance framework. They’ll make recommendations for improvements, which will serve as a roadmap for what needs to be accomplished in the coming year.
For instance, your auditors may flag issues such as gaps in your Gen AI risk assessments or insufficient controls over Gen AI-powered processes. Rather than viewing these findings as setbacks, consider them opportunities to strengthen your security posture and stay compliant.
For small and emerging businesses, staying compliant with SOC 2 while adopting Gen AI-driven solutions may seem daunting. Having navigated the process to earn SOC 2 attestation at Aidentified, we have learned that it is important to involve your SOC 2 auditor early in your Gen AI onboarding process to get their input prospectively on Gen AI technology implementations. With a proactive approach and a commitment to continually improving your security practices, you can successfully navigate the complexities of Gen AI while keeping your company secure and your SOC 2 process updated.
About the Author
Juliana Spofford has over 30 years of experience providing legal advice to data services and information technology companies, such as NetProspex, Inc. (sold to Dun & Bradstreet) and Generate, Inc. (sold to Dow Jones). Prior to joining Aidentified, Juliana was the global Chief Privacy Officer at Dun & Bradstreet where she was responsible for their global privacy compliance program. Juliana can be reached at https://www.aidentified.com/
