SOC 2 · P - Privacy
SOC 2 P5.1: P5.1 Data subject access
SOC 2 P5.1 covers P5.1 Data subject access. The held text names 4 evidence records for it, the first being Data subject access request procedure and log. The common gap an assessor flags is No identity verification before disclosure.
Identified and authenticated data subjects can see their stored personal information and, on request, receive physical or electronic copies; if access is denied they are told why, as objectives require. Points of focus: identity is authenticated before access is given; people can find out whether information about them is held and obtain it; it is provided in an understandable form, in reasonable time and at reasonable cost; and denials are explained promptly unless law prohibits it. The 2022 revision adds, for data processors, a process to act on data subject requests passed on by data controllers under the service agreement, including authenticating them, giving access where appropriate, answering in reasonable time and notifying any denial.
What evidence supports P5.1?
- Data subject rightsData subject access request procedure and log
- Data subject rightsIdentity verification steps
- Data subject rightsResponse time metrics against commitments
- Data subject rightsProcedure and log for access requests received from customers acting as controllers (processor role)
Where this requirement comes from
This is our own statement of SOC 2 P5.1, read from the copy we hold (issuer free complete copy) and stated in our words, not the standard verbatim. The framework as we hold it.
Common gaps an assessor flags
- No identity verification before disclosure
- Requests exceed the committed response time
- Responses omit data held in secondary systems
How it maps to ISO 27001:2022
No reviewed link is held for this control.
A link is a topical overlap with a confidence and a reason. It does not establish that meeting one requirement satisfies the other, and it is not certification.