How to Make Security a Selling Point: SOC 2, Trust Pages and AI Data-Use Answers
By Saroj Jha · October 4, 2026 · 16 min read
Write down where buyers’ data goes and whether it trains any model, publish that on a dated trust page, start a SOC 2 audit only when a real deal needs one and the controls already run, answer questionnaires from one reviewed library, and claim only what you can show.
In three numbers
- 5 areas a SOC 2 examination can cover: security, availability, processing integrity, confidentiality and privacy. Always say which yours covers[1]
- 2022 the edition every ISO/IEC 27001 certificate now follows; certificates to the 2013 edition expired or were withdrawn by October 31, 2025[2]
- $0 to publish your answers to the Cloud Security Alliance’s standard CAIQ questionnaire in its public STAR Registry, as a Level 1 self-assessment[3]
The email usually arrives after the good call. A prospect likes your demo, then their security team sends a spreadsheet of questions, and the deal waits until you answer it. If your product sends their data to a language model, one question gets sharper: will our data be used to train it?
Most startups meet this moment unprepared. There is no trust page, no written answer on model training, no one who owns the spreadsheet, and sometimes a line in a sales deck about being “enterprise-grade secure” that nobody can back up. Security is engineering work. Selling it is a writing job, and the writing can start long before an audit. A data-use page, a trust page and an answer library will carry most reviews. One overstated sentence can lose the deal.
Below are five steps, in the order you build them, each followed by one thing to do this week. It is orientation and AAJ’s judgement, not legal or security advice, and not a guarantee of results. It does not cover sector law such as HIPAA, and it does not teach you to pass an audit. If your product touches regulated data, get counsel involved early.
Running case: Example Co. Fictional
Example Co. is a fictional AI assistant for support teams. It reads incoming support tickets, sends the ticket text to a language model run by an outside provider, and returns a suggested reply. It has eight people and no security hire. It is a different fictional company from the Example Co. in the developer marketing post. Example Co., its pages and every detail about it are illustrative.
Good demo
- The ask The buyer asks You hand over Built in
- 1 Data questions
The buyer asks“Where does our data go, and is it used to train models?”
You hand over A one-page data-use answer and a subprocessor list
Step 1 - 2 Trust page
The buyer asks“Is there security information we can read without asking?”
You hand over A dated trust page with the data-flow picture and a way to request documents
Step 2 - 3 Questionnaire
The buyer asks“Please complete our security questionnaire.”
You hand over Answers from one reviewed library, sent on time
Step 4 - 4 Audit report
The buyer asks“Do you have a SOC 2 report or something equivalent?”
You hand over A report, or honest evidence of what you have today
Step 3 - 5 Contract terms
The buyer asks“Will you put these promises in the contract?”
You hand over Claims that match the paper, and a change log
Step 5
Signed contract
Step 4 Step 3 The asks arrive in this order, but you build in step order, so Steps 3 and 4 swap.
My judgement: a typical order of asks, not a rule. Your buyer may ask in a different order or skip a step.
Figure 1 shows a typical path. Your buyer may ask in a different order or skip a step, and the steps below follow the order you build things, not the order of the asks.
Step 1: Answer the three data questions first
Before a buyer reads anything else, they want three answers. Where does our data go? Is it used to train a model? Who can see it? If you can answer those in one page, the rest of the review gets easier, because you have shown you know your own system.
Example Co.’s one-line description already answers the first question: ticket text goes to an outside model provider. That is the catch for any AI startup: Example Co.’s promise about training can be no broader than its provider’s terms and its own contract with that provider.
So start by checking what your provider says, for the plan you actually use. Two examples, checked again on October 14, 2026: Anthropic’s privacy page[4] (dated August 18, 2026) says inputs and outputs from its commercial products are not used to train its models by default, with feedback a user chooses to send, or data a customer opts to share, as the exceptions. OpenAI’s business data page[5] says its business products and API platform do not use inputs or outputs for training by default, with an explicit opt-in. Both are vendor pages and both can change. One trap: these defaults cover business and API plans, and a consumer plan may differ. Date what you found and keep a copy.
Then check your own product, because the provider is only one of the places data can go. Do you log ticket text? Do your own thumbs-up and thumbs-down buttons send ticket text to a set your team uses to improve prompts? Do you use customer data to evaluate or fine-tune anything? Any “yes” belongs in the answer. The most common way to get this wrong is a flat “we never train on your data” that is true of the provider and untrue of your own logging.
Write the answer as a short page a buyer can forward. For Example Co., it would read like this (all details illustrative):
example.com/data-use Fictional
How Example Co. handles your data
- What data does Example Co. process? The text of support tickets that a customer connects.
- 1 Where does it go? To one language model provider, through that provider’s business API, and to our own database, hosted in [region].
- 2 Is it used to train models? Ticket text is not used to train the provider’s models under the terms of our agreement. We do not train our own models on it. Feedback buttons store the rating only, not the ticket text. [Edit this line to match what is true.]
- How long do we keep it? [30] days, then deleted. The provider’s retention is set out in its terms: [link].
- 3 Who can see it? [Role-based access, named staff roles.] Our staff can read ticket text only after a customer opens a support request, and that access is logged.
1 2 3 The three questions buyers ask first. Replace bracketed text with what is true.
Add a list of subprocessors, which are the outside companies that process your customers’ data on your behalf: the model provider, your cloud host, your help-desk integration and any logging service. Buyers ask for it because every name on it is one more place their data can go. Figure 2 shows the same flow for Example Co.; draw yours the same way, and the page writes itself.
- Customer’s help desk The customer’s own system
- ticket text reply
- Example Co. app Drafts the suggested reply
- ticket text reply
- 1 Model provider Through its business API Outside company
- stored [30] days, then deleted
- 2 Database On the cloud host Outside company
The subprocessor list on the trust page Fictional
Company What it does with customer data Where 1 Model provider Drafts the suggested reply from the ticket text [region] 2 Cloud host Hosts the app and the database that keeps ticket text for [30] days [region]Not a third place: the feedback button now stores the rating only, not the ticket text (fixed in Step 1).
Example Co.’s flow from Step 1. Fictional; bracketed values are placeholders a real company replaces.
When the data flow fits in one picture, the one-page answer is easy to write and easy to keep true. When it does not, that is a finding too.
Example Co., step 1 Fictional
The founders write the five-line page above, list two subprocessors (the model provider and the cloud host) and discover that their own feedback button has been storing ticket text alongside the rating. They change it to store the rating only, and the page stays true.
Do this
Write the five-line data-use page for your product, date it, and have your engineer confirm every line against a setting or a contract.
Step 2: Build a trust page
A trust page, sometimes called a trust center, is a public page where you publish your security and privacy facts. It does one job: it lets a buyer’s security team answer their first questions without waiting for you. A prospect who finds a clear page before the call arrives with fewer questions, and the questions that remain are the real ones.
You do not need special software. A single page on your own site works, and a page that is honest and dated beats a polished one with gaps. Figure 3 shows what Example Co. would put on it. Each block answers one buyer question, and only one needs a request.
example.com/trust
Example Co. trust page
Last updated [date] Owner: [name] Fictional
- 1 What data we process Public — Types of data, where it goes and the model-training answer: the Step 1 page
- 2 Subprocessors Public — Company, purpose, location and the date the list last changed
- 3 Keeping data safe Public — Access, encryption and backups, in plain words, and only what is true
- 4 Retention and deletion Public — How long data is kept, and how a customer asks for deletion
- 5 Certifications and reports Public — Exact scope and date, or the words “none yet” — Example Co.“None yet. Our model provider publishes its own reports; see the subprocessor list.”
- 6 Policies and audit reports On request — Sent on request, under a confidentiality agreement — Example Co. Request by email; reply within five working days
- 7 Security contact Public — One named mailbox, and the reply time — Example Co. One mailbox, named on the page
Example Co.’s page from Step 2. Fictional and generic: the layout is illustrative, not any real company’s page.
Three choices matter more than the layout.
Publish only what you can stand behind. Every block should be something a person on your team can explain and show. If your encryption story is not clear to you, do not borrow words like “bank-grade” for it. Leave the block out until it is true and specific. Step 5 gives the wording rule in full.
Put the data-use answer from step 1 near the top. For an AI product, it is the block buyers look for first. Link it from your pricing page and from the signup flow too. A trial user who is evaluating you for their company is running a small security review of their own.
Gate what needs a confidentiality agreement, and say how to ask. Policies and audit reports are usually shared on request, under a confidentiality agreement; check the terms of any audit you commission. The page should say what you will send, who to write to, and how long you take to reply. Make the reply time one you can keep, which is the subject of step 4.
Put a “last updated” date at the top and change it only when something changes, and give the page one named owner so it does not drift after the first week.
Example Co., step 2 Fictional
The founders publish a single page on their own site with the seven blocks in Figure 3. The certifications block reads “None yet. Our model provider publishes its own reports; see the subprocessor list.” The page names a mailbox and a five-working-day reply time for document requests.
Do this
Publish the seven blocks you can fill today, leave out the ones you cannot, date the page and name its owner.
Step 3: Decide whether you need SOC 2 yet
SOC 2 is the question I am asked most, so start with what it is. The AICPA[1], the professional body of US accountants that publishes the standard, describes SOC 2 as an examination of controls at a service organization that are relevant to security, availability, processing integrity, confidentiality or privacy. A CPA firm carries out the examination and writes a report. That is why I avoid the phrase “SOC 2 certified”: what exists is an auditor’s report on your controls, with a scope and a date or a period, not a certificate that you hold.
Three details change how you talk about it. First, the five areas are the menu, and a report can cover some of them. Always say which. Second, the use of a SOC 2 report is generally restricted[6], while a SOC 3 report covers the same areas in less detail and can be freely distributed[7]. That is why the full report sits behind a request in Figure 3. Third, there are two types: a Type 1 gives an opinion on the design of your controls as of a date, and a Type 2 adds whether they operated effectively throughout a period[6]. Ask the buyer which type they expect before you commit.
If a buyer asks for ISO/IEC 27001 instead, that is a certificate, from an accredited certification body[8], and since October 31, 2025 it must follow the 2022 edition[2]. Figure 4 compares the four kinds of report.
- SOC 2 Type 1 Auditor’s report — Covers An opinion on the design of your controls — Issued by A CPA firm — Who may see it Generally restricted: send on request, under a confidentiality agreement — What you can say“A SOC 2 Type 1 report covering [areas] as of [date]”
- SOC 2 Type 2 Auditor’s report — Covers Type 1’s opinions, plus whether the controls operated effectively — Issued by A CPA firm — Who may see it Generally restricted: send on request, under a confidentiality agreement — What you can say“A SOC 2 Type 2 report covering [areas] for [period]”
- SOC 3 Auditor’s report — Covers The same areas as SOC 2, without the same level of detail — Issued by A CPA firm — Who may see it General use: it can be freely distributed, so it can sit on the trust page — What you can say“Our SOC 3 report, linked here”
- ISO/IEC 27001 Certificate — Covers Your information security management system, against the 2022 edition — Issued by An accredited certification body — Who may see it A certificate you can show, within the certification body’s rules for using it — What you can say“ISO/IEC 27001 certified”, with the scope: the one place “certified” is right
The five areas a SOC 2 or SOC 3 report can cover A report can cover some of them; always say which
- Security
- Availability
- Processing integrity
- Confidentiality
- Privacy
For AI: ISO/IEC 42001, published in December 2023, sets requirements for an AI management system.
AICPA: the SOC 2 guide, updated as of October 15, 2022[1], and the SOC 3 page[7]; Journal of Accountancy (AICPA), 2016, for the two types and the use restriction[6]; ISO[8],[9]; International Accreditation Forum, IAF MD 26:2023[2]. Simplified, not audit advice. The wording in the last row is my suggestion.
Now the decision. I would not start an audit because a competitor has one, or because a template says startups should. I would start when a real deal needs it and the controls behind it are already running. Figure 5 turns that into three questions.
Start A buyer asks for a SOC 2 report
- 1 Is the deal blocked without a report, in writing? Ask the buyer, and keep the answer. Example Co.’s was no Fictional Yes If no Send the Step 1 and 2 materials and a completed questionnaire. Revisit later.
- 2 Are your controls already running and written down? Who gets into production, how changes are approved, how vendors are reviewed, how access is removed Yes If no Build the controls first. Tell the buyer your plan and a date you can keep.
- 3 Is the deal, and the pipeline behind it, worth the work? Quotes from two or three auditors, for your scope and period Yes If no Offer the same materials. Reassess when the next large deal asks.
Engage an auditor, and agree with the buyer which report type they expect.
My judgement, from Step 3. Steps 1 and 2 are the data-use answer and the trust page. Example Co.’s answer is from the running case.
The second question matters most and gets skipped most. An auditor examines controls that exist: who can get into production, how changes are approved, how you review vendors, how you remove access when someone leaves. If those live in people’s heads, the first job is to write them down and run them, and the audit comes after.
I will not quote a cost, a timeline or a share of deals that ask for a report. The figures in circulation come from companies that sell compliance software, and your scope sets the price. Ask two or three auditors for quotes, what your scope and period would need to be, and how they tailor the work to you. In May 2026 the AICPA warned peer reviewers about SOC 2 engagements with identical reports, risk assessments, sample sizes and testing procedures, which are not performed in accordance with professional standards[10].
Until the answer is yes, you still have plenty to offer: the data-use answer, the trust page, the subprocessor list, written policies you follow, and complete answers to the questionnaire. If your model provider publishes its own reports, you can say so. OpenAI’s business data page[5], for example, says it aligns with the SOC 2 Type 2 Trust Services Criteria and points to a trust portal for verification; check the portal for scope and date. Be clear about whose report it is. Your buyer is asking about you, and a provider’s report covers the provider. “Our model provider publishes SOC 2 documentation, which we have checked; we do not hold a report yet, and here is what we do instead” is a strong sentence, but only if you have read the provider’s own page first.
Example Co., step 3 Fictional
A prospect’s procurement team asks for a SOC 2 report. The founders ask whether the deal is blocked without one, and the answer, in writing, is no: a completed questionnaire and the trust page will do for this year. They write down their access, change and offboarding controls anyway, so that the next time the answer is yes they are ready to start.
Do this
Answer the three questions in Figure 5 in writing. If any answer is no, write down what you will send the buyer instead and when you will revisit.
Step 4: Run questionnaires as a pipeline
A security questionnaire is a long spreadsheet or portal form that a buyer’s team asks you to complete. Some are standard, such as the Cloud Security Alliance’s CAIQ, a yes-or-no questionnaire on cloud security controls[11]; you can complete it once and publish it free in CSA’s public STAR Registry[3]. The first one is painful. By the tenth, most of it should be reuse, if you built the pipeline after the first. The goal is that every question is answered once, by the person who knows, and reused after that.
The heart of it is an answer library: one shared document where each approved answer has a short text, a link to the evidence behind it, an owner and a review date. AAJ’s Security Questionnaire Answer Library is that document as a free workbook, with the request log, subprocessor list and change log beside it. Example Co.’s library might start like this (all entries illustrative):
| Topic | Approved answer, in one line | Evidence | Owner |
|---|---|---|---|
| Model training | Ticket text is not used to train models, ours or our provider’s | Provider terms, our contract | Founder |
| Data location | Stored in [region] with our cloud host | Hosting settings page | Engineer |
| Access when staff leave | Access is removed on the last working day | Offboarding checklist | Engineer |
| Subprocessors | Two outside companies, listed on our trust page | Trust page | Founder |
The evidence column does the work. If you cannot name a document, setting or record that proves an answer, it is not ready for the library.
Figure 6 shows the pipeline around it: log the request and its due date, match each question to the library, and send the gaps to the person who knows, usually an engineer. A different person then checks every claim against the evidence before you send it on time and add the new answers to the library.
- 1 Log the request One owner, a due date Process owner
- 2 Match to the library Reuse approved answers Process owner
- 3 Route the gaps To the person who knows, usually an engineer Truth owner
- 4 Review every claim Against written evidence, before anything is sent Reviewer
- 5 Send on time With a named contact Process owner
- 6 Update the library So the next one is faster Process owner
Next questionnaire: back to step 2, with a bigger library
Example Co.’s first two questionnaires Fictional
First 180 questions, two weeks All written new; they start the library Second Another buyer About two thirds from the library NewAnswered from the library Written new, then added to the library
Show the numbers as a table| Example Co. (fictional) | Questions | Answered from the library | Time |
|---|---|---|---|
| First questionnaire | 180 | None: these answers start the library | Two weeks |
| Second questionnaire, another buyer | Not stated | About two thirds | New answers added the day it is sent |
The pipeline is my judgement, from Step 4. Example Co.’s questionnaires are from the running case and are fictional; bars show shares of each questionnaire, drawn to scale.
Three rules keep it fast and true.
One owner for the process, another for the truth. In an early-stage company the founder or a marketer can own the process: the log, the deadline, the library. The engineer owns whether an answer is true. Sales should not answer security questions from memory in an email, and a simple rule that all of them go through the log prevents most of the damage.
Set a reply time you can keep. It is the same habit as a lead-response agreement: a named owner, a time limit, and someone who checks it. Publish the time on the trust page and measure yourself against it.
Say no when the answer is no. If you do not do something, say so, and say what you do instead or when you plan to. A “no, not yet, planned for [date]” is fair only if the plan is real. A yes you cannot prove can cost you the deal and the relationship.
Example Co., step 4 Fictional
The first questionnaire has 180 questions and takes the founders two weeks. They start the library with every answer they wrote, each with its evidence and owner. About two thirds of the second questionnaire, from a different buyer, comes straight from the library, and the new answers go into the library the same day it is sent.
Do this
Download the Security Questionnaire Answer Library and fill five rows, one per question you have already been asked, each with its evidence and its owner.
Free template
Start the answer library after your first questionnaire
The free Security Questionnaire Answer Library keeps the request log, one approved answer per question with its evidence and owner, the subprocessor list and a change log, with Example Co. filled in.
Get the libraryStep 5: Keep every claim true
Everything above fails if one sentence is wrong. Buyers read security claims closely. A buyer’s team may compare your page to your questionnaire, the questionnaire to the contract, and the contract to what your engineer says on a call. A mismatch can cost more than the missing feature would have.
I use one rule: say only what you can show, at the level you can show it. The table below sets out wording by the evidence you hold. The examples use Example Co. and are illustrative, not legal text.
| Evidence you hold | You can say | Do not say |
|---|---|---|
| A written policy you follow, no outside review | “We have a written access policy and follow it. Here is the document.” | “Certified,” “audited” or “compliant” |
| Your own completed questionnaire | “These answers are accurate as of [date].” | “Fully secure” or “meets all your requirements” |
| Your model provider publishes SOC 2 documentation you have checked | “Our provider publishes SOC 2 documentation. We do not hold a report yet; here is what we do instead.” | “We are SOC 2 compliant” |
| Your own SOC 2 report from an auditor | “We have a SOC 2 [Type 1 or 2] report covering [areas] for [date or period]. Available under a confidentiality agreement.” | “SOC 2 certified,” or any area the report does not cover |
| A contract term that bars training on customer data | “Under our agreement with our provider, ticket text is not used to train models.” | “We never use your data for AI,” if your own logs, feedback or testing do |
Three habits support the table.
Make the paper match the page. What you promise on the trust page, in the questionnaire and in the contract has to be the same, and Figure 7 shows the check. If sales promises more in an email than the contract gives, the contract is what counts, and the buyer will notice the difference.
- What each promises Trust page Questionnaire answers Draft contract
- Model training Not used Not used Not used
- Subprocessors Two, listed Two, listed Two, listed
- Retention of ticket text 30 days 30 days 90 days 30 days Fixed to match
Change log Fictional
[date] Contract template: retention changed from 90 to 30 days, to match the trust page and the questionnaire.
Show the numbers as a table| Promise (fictional) | Trust page | Questionnaire | Draft contract |
|---|---|---|---|
| Model training | Not used | Not used | Not used |
| Subprocessors | Two | Two | Two |
| Retention of ticket text | 30 days | 30 days | 90 days, fixed to 30 |
Example Co.’s quarterly check from Step 5. Fictional; the training and subprocessor rows follow its Step 1 page.
Do not change data practices quietly. In February 2024, staff in the US Federal Trade Commission’s Office of Technology and Division of Privacy and Identity Protection warned in a blog post[12] that it may be unfair or deceptive for a company to adopt more permissive data practices and tell its customers only through a surreptitious, retroactive change to its terms. The post is aimed at AI companies, but it says any firm that reneges on its privacy commitments risks running afoul of the law. If you ever want to use customer data in a way your page rules out, such as training, do not edit the page and hope. Tell customers first, get the agreement your contract requires, and ask a lawyer how.
Keep a change log. Add a short dated note each time your answer to any of the three data questions changes: a new subprocessor, a new retention period, a new provider. It takes a minute, it feeds the “last updated” date on the trust page, and it gives you something to point to when a buyer asks what changed since last quarter. For customers covered by the GDPR, adding a subprocessor needs their written authorization and, under a general authorization, advance notice so they can object[13],[14].
Example Co., step 5 Fictional
Before a contract review, the founders put the trust page, the questionnaire answers and the draft contract side by side. The questionnaire says data is kept for 30 days; the contract draft says 90. They fix the contract, add a line to the change log, and the review passes without a question.
Do this
Once a quarter, read your trust page, your questionnaire library and your standard contract together and fix every place they disagree.
What changes by stage?
- Pre-seed — The data-use page and the subprocessor list, written by the founder and checked by whoever runs production. Nothing else yet.
- Seed — A trust page on your own site, an answer library after the first questionnaire, and written access, change and offboarding controls you actually run.
- Series A and B — The audit decision in step 3, a named owner for security requests, and a quarterly check that the page, the library and the contract agree. Larger buyers run the approval path the ABM playbook describes; build the material before the first big deal needs it.
What mistakes should I avoid?
- Writing “SOC 2 certified” or “compliant” anywhere.
- A trust page that nobody dates or owns.
- Letting sales answer security questions from memory in an email.
- A “we never train on your data” line that is true of the provider and untrue of your own logs.
- Describing your provider’s audit report as if it were yours.
- Starting an audit before the controls exist.
- Changing a data practice and updating the page afterwards, quietly.
Example Co. is a fictional company. Its pages, answers and details are illustrative. This post is orientation, not legal or security advice.
Related on AAJ
Articles
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- Privacy and Advertising Rules for Startup Marketers: What to Check Before You LaunchConsent, email and claims rules for the same customer data, including AI claims.13 min read
- How to Market an AI Product (When Every Product Says It Has AI)Prove what your AI does before buyers ask what it does with their data.9 min read
- How to Sell EdTech to School DistrictsThe education version of this paperwork, with student-privacy agreements.11 min read
Playbooks
- Marketing AI Products Playbook: Position, Prove, Price, SellProving an AI product’s claims to buyers, security review included.
- Account-Based Marketing Playbook: 6-Stage B2B FrameworkRun the security review as one stage of an enterprise deal.
Templates and tools
- Security Questionnaire Answer LibraryThe working file for Step 4: request log, answers with evidence and owners, subprocessors and change log.Free template
- Lead Scoring and SLA SheetThe response-time habit, built for leads and reusable for security requests.Free template
- Claims & Proof CheckerFlag every claim on the trust page that needs evidence before it goes live.Free tool
- AI Tool PolicyDecide which AI tools may touch customer data before a buyer asks.Free template
References
The superscript numbers in the article match this list.
All pages were checked again on October 14, 2026. Vendor pages are labelled as such and can change.
- AICPA. “SOC 2® Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy.” Guide, updated as of October 15, 2022. What a SOC 2 examination covers; performed by CPAs in public practice. aicpa-cima.com
- International Accreditation Forum (2023). IAF MD 26:2023, Transition Requirements for ISO/IEC 27001:2022, Issue 2. Certifications to ISO/IEC 27001:2013 expire or are withdrawn at the end of the transition, October 31, 2025. iaf.nu
- Cloud Security Alliance. “STAR.” The Security Trust Assurance and Risk program and its public registry; the Level 1 self-assessment is “a complimentary offering”. cloudsecurityalliance.org
- Anthropic Privacy Center. “Is my data used for model training?” Vendor page dated August 18, 2026, checked October 14, 2026. Inputs and outputs from commercial products are not used for training by default; feedback, or data a customer otherwise chooses to share, is the exception. privacy.claude.com
- OpenAI. “Business data privacy, security, and compliance.” Vendor page, no date shown, checked October 14, 2026. Business and API data not used for training by default, with an explicit opt-in; says its practices align with the SOC 2 Type 2 Trust Services Criteria and links verification documents through its trust portal. openai.com
- Bourke, J. C. (2016). “Explaining the 3 faces of SOC.” Journal of Accountancy (AICPA), June 13, 2016, archived. Type 1 and type 2 reports; SOC 2 use “generally” restricted; SOC 3 use not restricted. journalofaccountancy.com
- AICPA. “SOC 3® - SOC for Service Organizations: Trust Services Criteria for General Use Report.” SOC 3 reports address the same areas as SOC 2 without the same level of detail, so they are general use reports that can be freely distributed. aicpa-cima.com
- International Organization for Standardization. “ISO/IEC 27001:2022, Information security management systems.” Edition 3, published October 25, 2022, amended 2024. Certificates come from accredited conformity assessment bodies, and certification is optional. iso.org
- International Organization for Standardization. “ISO/IEC 42001:2023, AI management systems.” Edition 1, published December 18, 2023. iso.org
- Kindem, T. (2026). “AICPA guides peer reviewers to address SOC 2 risks.” Journal of Accountancy (AICPA), May 14, 2026. Engagements with identical reports, risk assessments, sample sizes and testing procedures are not performed in accordance with professional standards. journalofaccountancy.com
- Cloud Security Alliance. “STAR Level 1: Security Questionnaire (CAIQ v4.1).” Released January 27, 2026. Yes-or-no questions on the security controls of a cloud service, used for STAR Registry submissions. cloudsecurityalliance.org
- US Federal Trade Commission, Office of Technology and Division of Privacy and Identity Protection. AI (and other) Companies: Quietly Changing Your Terms of Service Could Be Unfair or Deceptive, February 13, 2024. The “unfair or deceptive” and “surreptitious, retroactive” wording. ftc.gov
- Regulation (EU) 2016/679 (General Data Protection Regulation), Article 28(2): a processor engaging another processor. eur-lex.europa.eu
- European Data Protection Board (2021). “Guidelines 07/2020 on the concepts of controller and processor in the GDPR”, version 2.1, paragraph 128: prior authorisation of sub-processors and the controller’s opportunity to object. edpb.europa.eu
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