Preparing for SOC 2? Don’t Forget to Document How Your Company Uses AI

Artificial intelligence (AI) tools are becoming common in everyday business operations. Companies use them to write code, summarize documents, answer customer questions, and analyze information. While these tools can save time, they can also create security and privacy risks. If your company is preparing for SOC 2, documenting how you use AI should be part of your security preparation.

SOC 2 is a framework that helps businesses demonstrate how they protect customer data. Auditors may review your security policies, access controls, vendor management, and other practices. If AI tools handle company or customer information, your business should understand those risks and explain how they are managed. 

Documenting these activities helps your company understand AI related risks and determine whether its existing security controls are sufficient. A SOC 2 gap assessment can help identify areas where your current controls may need improvement.

Here is how to prepare your AI documentation before your SOC 2 audit.

Why Does AI Documentation Matter for SOC 2?

Many companies use AI without having a clear record of which tools employees access or what information they share with them.

For example, an employee might paste customer information into an AI chatbot to prepare a report. A developer might use an AI coding assistant while working on an application. Another employee might upload an internal document to summarize it.

These activities may expose sensitive information if the tools are not approved or configured properly. SOC 2 does not automatically require every company to stop using AI. Instead, your company should identify relevant risks, establish appropriate safeguards, and maintain evidence that those safeguards are followed.

Clear documentation helps your team make informed decisions and answer questions from customers, auditors, and business partners.

1. Build an Inventory of AI Tools

Start by creating a list of AI services your company uses. Include tools purchased by the business and tools employees use independently for work.

Your inventory should cover:

• Tool name: Record the AI platform or application.
• Business purpose: Explain why your team uses it.
• Users: Identify the employees or teams with access.
• Data shared: Record whether the tool processes public, internal, confidential or customer information.
• Vendor details: Document the provider and relevant security information.
• Approval status: Identify whether the tool has been reviewed and approved.

Check with each department to identify the AI tools employees use, the information they enter, and the people who can access those tools. This helps uncover services that may not have gone through your company’s approval process.

For example, your inventory might include an AI writing assistant used by marketing, an AI coding tool used by developers, and a chatbot integrated into your website.

This list gives you a starting point for understanding where AI-related risks may exist.

2. Identify Risks and Sensitive Information

Once you have an inventory, review how each tool handles information.

Ask these questions:-

• Which AI services process company or customer data?
• What sensitive information might employees share?
• Does the tool store prompts or uploaded files?
• Who can access the information?
• Can the provider use submitted data to improve its models?
• How long is the information retained?

The answers will depend on each provider’s terms, settings, and product features. Do not assume every AI service handles data in the same way.

For example, uploading customer information to an unapproved AI tool may expose sensitive data and violate company policies, contractual commitments or applicable privacy requirements. Your company may need a rule prohibiting this activity or allowing it only through an approved service with suitable safeguards.

Document the risks you identify and the steps taken to address them. A cybersecurity assessment service can also help your team review existing controls and identify gaps in its approach.

3. Assign Clear Ownership

AI security should not be left entirely to individual employees. Someone must be responsible for reviewing tools, approving their use, and checking whether company rules are followed.

For a small business, this responsibility might belong to the founder, IT lead, or security manager. Larger companies may divide responsibilities among security, legal, compliance, and department leaders.

Document who is responsible for:

• Approving new AI services.
• Reviewing vendor security and privacy practices.
• Managing employee access.
• Updating AI usage policies.
• Reviewing risks when a tool or its purpose changes.

Clear ownership helps prevent confusion and makes it easier to demonstrate accountability during a SOC 2 audit.

4. Connect AI Risks to Existing Security Controls

You do not necessarily need a separate security program just for AI. Many AI-related risks can be managed through controls your company already uses.

For example:

Review your existing SOC 2 controls to see whether they address AI-related risks. Depending on how your company uses AI, you may need to update security policies, restrict access to sensitive information, or strengthen vendor reviews. Document any changes and keep evidence to show that the updated controls are being followed.

A SOC 2 gap assessment can help identify missing or incomplete controls before your audit. Experienced SOC 2 compliance companies may also help businesses connect their AI practices with their existing compliance program.

5. Review AI Vendors and Keep Evidence

Examine an AI vendor’s security policies, data handling and storage practices, data access controls and security incident reporting procedures before selecting one. Find out if the provider complies with your company’s contractual and privacy standards and whether it uses customer data to train its AI models. Document your evaluation, any issues you find, and your ultimate choice to accept or reject the vendor.

Keep useful evidence, such as:-

• Your AI inventory and approved vendor list.
• AI usage and data handling policies.
• Vendor security review records.
• Access review results.
• Employee training records.
• Risk assessments and remediation plans.

Your company may also need to provide relevant policy documents, vendor review records or control evidence when responding to customer security questionnaires or auditor requests. Share only the information appropriate for the request and protect confidential details.

This evidence helps demonstrate that your company has identified AI-related risks and taken reasonable steps to manage them.

Businesses using SOC 2 compliance services should discuss AI usage with their advisors early. A qualified cybersecurity consultant can help organize documentation and prepare for questions that may arise during SOC 2 compliance audit services.

Make AI Documentation Part of Your SOC 2 Preparation

Documenting AI usage does not need to be complicated. Start with a simple inventory, assess how each tool handles information, assign owners and connect identified risks to existing security controls.

Review your documentation regularly, especially when introducing new tools or changing how employees use them. If you are preparing for SOC 2, cybersecurity services can help you evaluate your current security practices and address gaps before the audit. 

Whether you work with an external consultant or an internal team, the goal is the same: understand your risks, document your decisions, and protect customer information.

Prepare for SOC 2 with a Clearer View of AI Risks!

Documenting AI usage helps your business understand where sensitive information goes, who can access it, and how related risks are managed. Start by reviewing your AI tools, assigning responsibility and checking whether your existing security controls address the risks.

At SecurifyAI, we help businesses identify security gaps, assess risks, and prepare for compliance requirements through expert-led cybersecurity guidance.

We help you strengthen your security practices and prepare for SOC 2 with confidence. Contact our team to discuss your cybersecurity and compliance needs.

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