Do you need SOC 2 to license your company's data?

Why SOC 2 is rarely required of a data supplier#

SOC 2 is rarely required of a data supplier because it reports on controls over a system that serves customers, while a data license transfers a defined, prepared package. A buyer licensing records is not relying on your production environment to run its business.

A SOC 2 report is an independent CPA firm's examination of a service organization's controls against criteria covering areas such as security and confidentiality. Customers request it when they will store data in your product or depend on it daily. A data buyer's risk is different: whether the records are lawful to use, accurately described and free of personal details and secrets.

Reports come in two forms. A Type 1 report describes controls at a point in time; a Type 2 report also tests whether they operated over a period. Either way, the subject is a service, not a dataset.

Requirements are still set deal by deal. A buyer's procurement process may send a vendor security questionnaire, and some ask about certifications as part of it.

What buyers check instead#

Buyers check evidence about the dataset and its release, and most of it comes from the supplier's own records rather than an audit report.

Most of this evidence also protects the supplier. If a question arises later, it shows exactly what was released and under whose approval.

When a SOC 2 report does help#

A SOC 2 report helps when the licensing relationship starts to look like a service. If the buyer will receive recurring data feeds, use a staging environment you host, or connect to an API you operate, its security team may treat you as a vendor and ask for the report.

An existing report also shortens security questionnaires, since many answers can point to it. It does not replace dataset evidence: a SOC 2 report says nothing about whether a support archive was lawfully collected or properly prepared.

If you already have a report, run the licensing project through your existing controls, such as access reviews and change management, so it does not create an exception in the next audit period.

SOC 2 or ISO 27001 for a smaller company?#

For a smaller company, the choice between SOC 2 and ISO 27001 should follow customer demand rather than a licensing project, because neither is generally required to license data.

If customers already ask for one, pursue it for them. The controls you build will make dataset releases smoother, but you will still need the release evidence described above.

Release controls that matter for a dataset#

Release controls are the security measures buyers and counsel look for in a data license, and a company without any certification can put every one of them in place.

Record each control as it happens rather than reconstructing it afterward. A dated access list, a saved scan report and a signed authorization are far more convincing to a buyer's reviewer than a policy describing what should have occurred.

• 1Limit preparation access to named people, and remove that access when the project ends.
• 2Prepare data in a separate working copy, never inside production systems.
• 3Scan the delivery copy for credentials and personal details, and keep the results.
• 4Record a checksum manifest so both sides can confirm what was delivered.
• 5Deliver through encrypted transfer or encrypted drives, never ordinary email or open sharing links.
• 6Delete working copies when the license or project terms call for it.
• 7Keep a signed release authorization for each delivered version.

What to say when a buyer asks for your SOC 2 report#

When a buyer asks for a SOC 2 report you do not have, say so plainly and offer the evidence that addresses the buyer's actual concern. A short cover note works well: no SOC 2 report, the controls that apply to this release, and the documents attached.

Attach the release evidence rather than general policies. The scan results, delivery plan, checksum manifest and signed authorization speak directly to the dataset, while a stack of policy documents mostly shows that policies exist.

If the buyer's procurement rules truly require a report from every supplier, ask whether an exception process exists for one-time data transfers. Some procurement teams have one, particularly for suppliers that never connect to the buyer's systems.

Illustrative: a third-party logistics company without SOC 2#

Illustrative: a fictional third-party logistics company with warehouses in several states plans to license order exception records, WMS task histories and EDI error logs. It has no SOC 2 report, and its leadership worries that this will end the conversation.

The buyer's procurement team sends a security questionnaire. The company answers with its existing controls, its preparation plan, scan results for the delivery copy, and a delivery plan using encrypted drives with a checksum manifest. Its general counsel adds the rights review and the signed release authorization.

The buyer accepts the dataset evidence in place of a SOC 2 report. The company decides not to start an audit for licensing alone and will revisit the question only if its own warehouse customers begin asking.

How SourceX handles security evidence#

SourceX builds security evidence into the Delivery step of the SourceX five-step transaction. Large datasets stay in the supplier's own storage or ship on encrypted drives, SourceX never hosts multi-terabyte datasets, and the supplier approves every release.

The SourceX Evidence Packet ties the release authorization to the provenance, rights and privacy records, which covers most of what a buyer's security review asks about the data itself.