What CC2.3 external communication asks for in a SOC 2
CC2.3 asks the organization to communicate with external parties about matters that affect how its internal control functions. In plain terms, customers, vendors and other outside parties need to hear, through reliable channels, about the commitments you have made to them, the changes that could affect the service they depend on, and the incidents that touch their data or availability. The criterion restates COSO Principle 15, so an assessor will read it as a question about the outward side of your control environment rather than as a marketing or disclosure exercise. Customers rely on this communication because they cannot see inside your systems. A status notice, a change announcement or a breach notification is often the only signal they get that a control has failed or been altered, and their own compliance obligations may depend on how quickly and clearly that signal arrives. The difficulty is rarely the existence of a channel. Most organizations already email customers, post status updates and answer security questionnaires. The gaps appear when those channels are scattered across a support inbox, a sales team's shared drive, an account manager's memory and a public status page that nobody owns. Commitments made in contracts, security pages or questionnaire answers often drift apart from what engineering actually does. The practical first step is to inventory every outbound path that carries control-relevant information and to name an owner for each. Then confirm with your auditor how the examination will test those paths, since the assessor will ask for evidence that communications were sent, to whom and under what approval, not only for a written policy that says they should be.
Two decisions shape the work. The first is which commitments and notices belong in a single controlled source, such as a maintained trust page, a version-controlled set of customer-facing commitments and a documented incident notification procedure. The second is how inbound channels are staffed and tracked, so that a customer report of a suspected security problem reaches the right people and leaves a record. Confirm with your auditor and your legal counsel which external statements you must keep consistent, and ask whether your system description and the complementary user entity controls already describe what customers are expected to do on their side. Where a customer is a regulated entity, check whether its own rules set notice deadlines that your procedure must meet. Each of these questions produces a document, a named owner and an evidence trail, which is what the examination ultimately samples.
Which external parties and communications are in scope for CC2.3
CC2.3 covers every channel through which the organization tells outside parties about things that affect how its controls work. The cards below separate the parties, the message types and the scoping decisions that change how much work the criterion creates, so the team can define the boundary before the auditor asks for evidence.
Customers and their commitments
Customers are the party most often affected when a control changes. Commitments in contracts, order forms and public security pages describe what the service promises, and CC2.3 expects those statements to match how controls actually run. Check that the security commitments customers rely on are written down, owned by a named function, and updated when the system or the control changes.
Vendors and subservice providers
Hosting providers, managed database services and other subservice organizations sit on both sides of the boundary. The organization must communicate its own requirements to them and receive their notices about outages, security events or changes that affect the service. Confirm which vendor notices reach a named owner and how they are logged against the system description.
Regulators and the board
Regulators, supervisors and the board of directors are external or governance parties that need accurate information about control matters. Where a customer's regulator requires notice of an incident or a control weakness, the organization needs a defined route for that message. Confirm who speaks to the board about control matters and how those reports are recorded.
System changes and incident notices
Material changes to the system, such as a new data location, a changed subprocessor or a significant outage, often require outside notice. CC2.3 asks whether the organization tells affected parties in time and in a form they can act on. Define the thresholds for notice, the templates, and the approver before the first incident, not during it.
Inbound channels and separate lines
External parties need a way to report security concerns, ask questions and raise complaints. Points of focus under CC2.3 include enabling inbound communications and providing separate communication lines, so reports can bypass the normal chain when needed. Check that the security contact, the reporting address and the escalation path are published, monitored and tested.
Privacy category scoping
Including the privacy category adds points of focus to CC2.3 that are flagged in the NIST-hosted crosswalk to the 2017 Trust Services Criteria. These expand the outward communication expected about privacy practices, so the team should decide early whether privacy is in scope. Confirm the scope decision with the auditor, because it changes which notices and records must be produced.
How an assessor tests external communication
This table sets out each area an assessor is expected to look at for CC2.3, what the organization should be able to show, and where findings usually arise. Read it as a checklist for preparing evidence before fieldwork, since most gaps come from channels that exist in practice but were never written down or recorded.
| Assessor focus | What the assessor typically reviews | Evidence to prepare | Common findings |
|---|---|---|---|
| Commitments and system description | Whether the commitments given to customers match the system description and the controls described in the report | Customer-facing terms, security commitments, the system description, and a mapping from each commitment to an owning control | Commitments in contracts or trust pages that the system description does not cover, or that are out of date |
| Outbound change notices | A sample of notices sent to customers about system changes that could affect them, checked for timing, content and approval | Sent notices with dates and recipients, the change ticket they relate to, and the approval record | Changes that affected customers but were never announced, or notices sent without a record of who sent them |
| Outbound incident communications | A sample of notices about security or availability incidents, checked against the organization's own notification process | Incident records linked to customer notices, the notification procedure, and any contractual notice terms | Notices sent by ad hoc email with no ticket link, or procedures that name roles nobody holds in practice |
| Inbound channels | Whether the published channels for reporting security concerns, complaints or questions are monitored, and whether requests reach the right owner | Channel list (email aliases, forms, portal), routing rules, sample tickets from intake to closure, and monitoring ownership | Undocumented channels such as personal inboxes, requests received but not logged, or no evidence of a response |
| Vendor and regulator communication | How the organization informs vendors and external parties about matters that affect control, such as contract changes or regulatory notices | Vendor correspondence, contact registers, and records of any regulator notices with dates | Contact lists that are out of date, or external notices with no record of who approved them |
| Board communication | Whether matters affecting internal control reach the board or its committee and are minuted | Board or committee agendas and minutes, reports on security and availability, and follow-up actions | Board reporting that is informal or absent, or minutes that do not show a decision or follow-up |
| Separate communication lines | Whether there is a route for external parties to report concerns about internal control that bypasses normal management reporting | Published reporting route, the procedure for handling reports, and records of how reports were triaged | A route that is described in policy but never tested, or reports that were received but not tracked to resolution |
How to implement CC2.3 external communication step by step
This sequence turns CC2.3 from a policy statement into working channels, notice records and board reporting that an assessor can trace from a communication to the internal control it reflects. Each step ends with an artifact the auditor can inspect.
Identify external parties and communication types
Start by listing every external party that depends on or is affected by your internal control: customers, vendors and subservice providers, regulators, auditors, security researchers and the board. For each party, record the types of matters you must communicate, such as commitments, system changes, planned maintenance, security incidents, and changes to privacy practices where the privacy category is in scope. Owners in legal, customer success, security and engineering should review the list. The output is a communication inventory that names each party, the matter types and the trigger for each. Confirm the list against your system description and customer contracts before moving on.
Define published channels and owners
For each party and matter type, decide where the information is published or sent, such as a status page, a trust center, a contract notice clause, a customer portal or a regulator submission route. Assign a named owner and a backup owner to every channel so that someone is accountable when it changes. Record the channel register in a controlled location. The output is a channel register that shows party, matter, channel, owner and backup owner. Ask the owner of each channel to confirm in writing that they accept the role.
Set up a record for outbound notices
Create a versioned record for every outbound notice that touches internal control, including the notice text, date, recipients, approver and any follow-up. Wiki or documentation tools that keep version history and show who changed what are suitable for the notice templates and approved wording, while the sent notices themselves should be kept with their delivery evidence. Draft templates for the common notice types, such as a planned change to a production system or a notice of a security incident affecting customers. The output is a notice register and a set of approved templates that an assessor can sample.
Establish inbound contact points
Give external parties a way to tell you about problems with your controls. Publish a security contact, a vulnerability reporting address and a privacy contact, and route each to a monitored queue with a named triage owner. Include the same contact points in the trust center and in customer contracts. Test each address by sending a message and confirming that it reaches the queue and that someone responds. The output is a published inbound contact list and a log of test messages and triage responses.
Set board reporting on external matters
Agree with the board or its committee what external communication matters must be reported to them, such as significant incidents, customer complaints about security, regulator contacts and material changes to commitments. Define the format and frequency in writing and make sure the reports include the notices sent and the inbound issues received during the period. The output is board minutes or a board pack section that shows external matters reviewed and any actions the board requested. Ask the board secretary to keep the evidence with the control records.
Review the process periodically
Schedule a recurring review of the channel register, templates, contact points and board reporting. Check that each channel still exists, that owners are current, that contact addresses are monitored and that notices sent during the period match the approved templates. Log findings, assign corrections and confirm they are closed. The output is a dated review record with findings and remediation status. Keep these records for the observation period so that the auditor can test that the communication control operated throughout the period, which is the point of a Type 2 examination.
Using versioned documentation for external commitments
Every customer-facing statement about internal control needs a record of what changed, when and by whom. Under CC2.3, the statements an organization makes to customers, vendors and other external parties (its security commitments, its description of how the service works, its notices about system changes and its incident communications) are part of what an assessor tests. If a trust page says logs are retained for a set period, or a contract describes how customers are told about a material change, the organization must be able to show which wording was live on a given date and who approved it. Without that history, a Type 2 examination cannot tie what customers were told to what the controls actually did during the period.
Versioned wikis are one way to hold that record. XWiki, licensed under LGPL-2.1-or-later, keeps every change to a page under version control, records what changed, when and by whom, lets users compare any two versions and roll back to an earlier one. BookStack, under the MIT license, handles access differently: user abilities come from assigned roles, and permissions can be overridden per role at the shelf, book, chapter or page level. Together these illustrate two decisions to make: who may publish or edit a customer-facing page, and whether the history is strong enough to answer an assessor's question about the wording in effect on a past date. Both are illustrative options, so confirm with the vendors and your own environment that the version history, role model and export behavior meet your evidence needs before you commit a documentation tool to the program.
Evidence that passes CC2.3 and how to keep it current
CC2.3 is tested through records of what you told external parties and when you told them. The cards below cover the artifacts an assessor usually asks for, and the routines that keep each one complete across a Type 2 observation period, not just on the day of fieldwork.
Published commitments and system descriptions
Your public terms, security commitments and system description are the baseline external parties rely on. Keep each document under version control so you can show which version was live on any date in the observation period. Check that the system description matches what the platform actually does, including subservice providers and hosting locations. A stale description that contradicts current practice is a common source of exceptions. Record who approved each revision and when it was published.
Change notices sent to customers
When a change could affect customers' controls, such as a new data region, a retired feature or a changed authentication flow, the notice is the evidence that the change was communicated. Keep a log with the change, the audience, the send date and the channel used. Confirm that notices go out before the change takes effect where your commitments require advance notice. Assessors often sample changes from the change management records and then ask for the matching customer notice, so link the two.
Incident communications with timestamps
Customer and regulator messages about a security incident must show when the event was detected, when the decision to notify was made and when each external party was told. Keep drafts, final versions and send logs together, with timestamps from the mail or status page system. Review the templates at least once a year so that the first notice does not promise facts the team cannot yet support. Test one incident notice per period end to end so the trail is complete when an assessor samples it.
Inbound channel records and routing logs
CC2.3 expects external parties to be able to report problems and ask questions. Show the security contact, support queue and abuse mailbox, plus the routing rules that send messages to the right owner. Keep a ticket or message log with received time, assignee and resolution. Review the channels quarterly to confirm the addresses still work, forwarding is intact and departed staff no longer receive mail. An inbound channel with no logged activity raises the question of whether it is monitored at all.
Board communication minutes
Where the board or a board committee receives reports on security, availability or incidents affecting internal control, minutes are the evidence. Keep agendas, the materials presented and the recorded discussion and decisions. Check that the reporting cadence set out in your governance documents matches what the minutes show. Gaps in the record are easier to explain than a pattern of reports that were planned but never delivered. Confirm the exact board reporting requirements with your auditor before the period begins.
What meeting CC2.3 costs in money and effort
This table compares the cost components behind CC2.3, who is paid for each, whether it is one-time or recurring, and what moves it up or down. No prices or durations are stated because none were supplied, so use the table to shape a written quote and to see where self-hosted open source removes license spend.
| Cost component | One-time or recurring | Who is paid or who spends effort | What drives it up or down |
|---|---|---|---|
| Tooling and licenses for status pages, ticketing and inbound forms | Recurring | Software vendor, or no license fee if self-hosted open source is used | Number of channels and seats; self-hosting removes per-seat license spend but adds hosting and upkeep |
| Writing customer commitments, notice procedures and incident communication templates | One-time, then reviewed periodically | Internal legal, product and security staff, or an implementation partner | Number of customer contract types and whether commitments are already written in master agreements |
| Maintaining the public security and trust pages and changelog | Recurring | Internal marketing or engineering staff | How often system changes affect customers and how many channels must be kept in step |
| Setting up inbound channels and separate lines such as security contacts and abuse reporting | One-time setup, recurring monitoring | Platform engineering and security operations staff | Number of inbound channels, required response routing and after-hours coverage |
| Evidence upkeep: notices sent, acknowledgments, change announcements and version history | Recurring | Compliance lead and control owners | Volume of customer notices and whether records are kept in a version-controlled wiki or document system |
| Vendor and regulator communication records | Recurring | Vendor management and compliance staff | Number of critical vendors and regulated customers that require written communication |
| External review of notices and communication wording | Recurring, usually per engagement | Outside counsel, consultant or implementation partner | Scope of wording review and whether privacy category commitments are in scope |
| Auditor sampling and testing of external communication | Recurring, once per examination period | Independent CPA firm, with staff time to produce samples | Number of notices, incidents and changes in the period; well-indexed records reduce sample preparation |
Who owns CC2.3 and what a partner can prepare
Your organization owns CC2.3 in full. Management decides what it tells customers, vendors, regulators and other external parties about matters that affect internal control, and management is accountable for those statements being accurate. No partner or auditor can make those decisions for you, and the written description of the system must match what your people actually communicate. Expect these responsibilities to stay with named owners:
- Commitments and notices: Approving the security commitments you make in contracts, trust pages and questionnaires, and deciding when a change to the system requires advance notice.
- Incident communication: Deciding who speaks to customers after an incident, what is disclosed, and how quickly, with legal review built into the process.
- Inbound channels: Staffing the security contact, support queue or abuse address that external parties use to report concerns, and monitoring it.
- Board reporting: Presenting control matters to the board or its committee and recording what was discussed.
- Sign-off: Signing the management assertion and representation letter that the CPA firm relies on.
Check that each of these has a named owner and a backup, and that the owner can show who approved each external statement during the observation period.
An implementation partner such as DeployOpen can prepare the systems, templates and records that CC2.3 depends on, working inside your environment under a written scope. The partner does not decide your commitments, does not speak for your company to customers, and does not issue or sign any part of the SOC 2 report. Typical preparation work includes:
- Channel setup: Configuring a security mailbox or ticket queue, routing rules and escalation paths for inbound reports, in systems you host.
- Templates and drafts: Preparing notice templates, customer incident communication drafts and trust page content for your legal and security owners to approve.
- Records: Setting up a self-hosted wiki or documentation platform with version history, so every approved statement and its revision date can be shown later.
- Access and permissions: Configuring role-based permissions so only approved owners can publish external-facing content.
- Evidence collection: Organizing the emails, tickets, approvals and board minutes that show the communication controls operated.
The scope, deliverables and timeline should be agreed in writing before work starts. Ask the partner to state which items it will hand over and which remain your responsibility.
The CPA firm performs the examination under AT-C section 205 and issues the report. It tests whether your controls were designed suitably and, for a Type 2 report, whether they operated effectively over a period. Auditor independence means the firm cannot design, implement or operate the controls it tests, and it cannot prepare your system description or write your communication policies in a way that makes it responsible for them. Practical consequences for CC2.3 include:
- Testing: Requesting samples of external communications, incident notices, change notices and inbound tickets, then checking the approval trail.
- Exceptions: Reporting any notice that was late, missing or unapproved as an exception in the report.
- Representation letter: Relying on management's written statements, so your team must confirm them accurately.
- Engagement letter: Confirming in writing which services the firm will provide and where the boundary sits.
Ask your CPA firm early which preparation work it considers compatible with its independence, and get that answer in writing.
Most organizations outsource the mechanical parts of CC2.3 and keep the decisions. Outsourcing usually covers building channels, drafting templates, maintaining documentation systems and gathering evidence. Keeping in-house usually covers commitments, incident disclosure decisions, approval of external statements and communication with the board. Points to decide before engaging anyone:
- Decision rights: Which person can approve a customer notice without further sign-off.
- Evidence ownership: Where approved communications are stored and who can retrieve them for the auditor.
- Ongoing operation: Who monitors the inbound channel after the partner's project closes.
- Handover: Which configurations, runbooks and access credentials transfer to your team.
- Retention: How long communication records are kept, aligned with your policy.
When requesting a quote, ask the provider to list deliverables by owner so you can see what remains with your staff.
Independence is the line that matters most when a partner and an auditor both work on the same engagement. The partner prepares evidence and systems. The auditor decides whether the evidence supports the criteria. A useful test is whether a sentence in the report could be read as the partner's conclusion rather than the auditor's. Examples of crossing the line include the partner writing the control descriptions the auditor then certifies as operating, or the partner judging whether an exception is acceptable. Examples that stay on the right side include the partner building a notification template that management approves and the auditor tests.
- Separate contracts: Keep the implementation agreement and the CPA engagement letter distinct.
- Written boundaries: Ask both parties to state in writing who does what.
- Auditor review: Give the CPA firm the preparation scope before fieldwork begins.
- Record of decisions: Keep management's decisions in your own records, not only in the partner's tickets.
- Legal input: Involve counsel when external communications have contractual or regulatory consequences.
Confirm these arrangements with your CPA firm before you sign the implementation agreement.
Where CC2.3 usually fails and how to close each gap
External communication failures rarely come from a missing policy. They come from promises made outside the control system, notices sent by no one in particular, and changes that customers learn about after the fact. Each card below names one gap an assessor tends to find, and the fix that gives the examiner something to test.
Commitments that live only in sales decks
Security and availability promises made during sales calls, in proposals or in questionnaire answers often go further than the controls the organization actually runs. CC2.3 expects external communications about matters affecting internal control to be consistent with how the system operates. Collect every customer-facing commitment into one register, tie each entry to the control that delivers it, and have the owner of that control approve changes to the wording before sales reuses it.
No owner for security notices
When a vulnerability, outage or data exposure affects customers, the first notice often waits until someone decides who should write it. Name a single accountable role for customer security notices, with a named deputy, and document the approval path and the channels used, such as email, a status page or a trust page. Test the process with a tabletop exercise and keep the record, because an assessor will ask who sent the last notice and how the decision was made.
Inbound security reports with no route
Researchers and customers who find a flaw often have nowhere obvious to send it, so reports land in a general support queue or a personal inbox. Publish a dedicated security contact, route it to a monitored queue with an owner, and log each report with receipt, triage and resolution dates. Check that the address on your website, security.txt file and questionnaires all point to the same place, since mismatched contacts are a common finding.
Changes shipped without customer notice
Material changes to hosting regions, subprocessors, data flows or service behavior can alter the system described in the report without customers hearing about it. Define which changes count as material, set a notice period in your terms, and connect the change management record to a customer communication step. Keep copies of notices sent and the list of recipients, so the examiner can see that communication followed the change rather than trailing it.
No board reporting record
CC2.3 includes communicating with the board about matters that affect internal control, but many companies brief leadership informally and keep no minutes. Set a recurring agenda item covering open incidents, control exceptions, inbound security reports and material vendor changes, and record the discussion and decisions in the meeting minutes. Ask your auditor which board materials they expect to review, since the form of evidence depends on how your board is organized.
Questions buyers ask about CC2.3 external communication
How much effort does CC2.3 external communication take to satisfy?
For most organizations the effort lies in a small set of recurring communications rather than a large new program. CC2.3 restates COSO Principle 15, which asks the organization to communicate with external parties about matters that affect how internal control functions. Effort depends on how many external audiences you serve, how often your commitments or system change, and whether you already have customer notices, status pages and vendor-facing contacts. Teams with a stable product and few customer commitments usually need less work than teams that ship changes weekly to many enterprise customers. Ask your assessor which communications they will sample, since that determines what evidence you must keep.
Can we meet CC2.3 in-house without an outside firm?
Yes, many organizations do. The organization owns its controls, so its own staff must define how external parties are told about security commitments, system changes and incidents, and must run those channels. An implementation partner can help set up the mechanics, such as versioned documentation, published contact routes and notification workflows on self-hosted platforms, and can prepare evidence. Only an independent CPA firm issues the SOC 2 report. If in-house staff lack time or experience with assessor expectations, consider a consultant for the design review, and confirm in writing exactly which tasks the partner performs and which remain yours.
What does the work need from our team day to day?
The work needs named owners for each external channel, a way to record what was communicated and when, and a review step before commitments change. In practice that means a security or support lead who approves customer-facing security statements, an engineer who confirms system changes are flagged to affected parties, and someone who monitors inbound security reports. Document these roles in your policies and keep the approved versions under version control so an assessor can see what changed, when and by whom. Plan for these responsibilities to recur for the whole observation period, not only at audit time.
How long does it take to be ready for CC2.3?
Readiness depends on your starting point, and no fixed duration applies to every organization. If your external channels, contact routes and change notices already exist and are written down, the remaining work is usually confirming they match your stated commitments. If they are informal, such as messages sent from personal inboxes, expect to design and document them first. For a Type 2 report, the controls must also operate across the observation period, so the timeline runs from when the channels are in place. Ask any partner or auditor to state its assumptions about your current state before accepting a timeline.
Do the privacy points of focus for CC2.3 apply to us?
They apply only when the privacy category is in scope for your SOC 2. The 2017 Trust Services Criteria add points of focus to CC2.3 for that case, and the NIST-hosted crosswalk to the criteria flags which ones. If privacy is not in your report, you do not need to address those points, though you should still communicate with external parties about security matters. If you include privacy, expect more attention to how you notify data subjects and customers about privacy practices and changes. Confirm the category decision with your CPA firm early, because it changes the criteria your report covers.
What should we ask a partner to include in a quote?
Ask for a written scope that lists each external channel in use, each communication type covered, and who performs each task. A quote should state deliverables, such as documented channels, notification templates, configured self-hosted tools and evidence packages, along with what the client must provide. Ask whether the partner prepares evidence only or also participates in auditor meetings, and whether any recurring support is included after handover. Confirm that the quote does not promise an audit outcome, since only an independent auditor issues the report. Fixed-scope agreements make these boundaries easier to compare across vendors.
Which external communications will an auditor most likely test?
Auditors usually test whether the commitments you publish to customers match what your team actually does. They may request copies of security commitments, examples of notices sent after system changes, records of incidents communicated to customers, and the process for receiving and acting on security reports from outside the company. Keep a dated log of significant external communications and link each entry to the control it supports. Ask your auditor which samples they plan to select so you can prepare the records before fieldwork begins.
Deciding between in-house work and a partner for CC2.3
The first decision is whether your team can write and run CC2.3 communication controls without outside help. Start with the depth of existing documentation: if you already have current customer commitments, a published description of how your service changes, a documented incident notification path to customers, and a named owner for inbound security questions, the work is mostly review and evidence collection. If those artifacts are missing, scattered across email, or out of date, the job becomes writing and approving them, which is where an implementation partner can save internal time. Then count the external parties who rely on your communications: customers, vendors, regulators, and any sub-processors or auditors who need notice of changes. Each additional party adds a channel, a template, and a record to keep. Finally, assess staff capacity honestly. Someone must own each communication path, approve wording, and keep the record current across the observation period, not just in the month before fieldwork.
Be precise about roles. Chainscore Labs' DeployOpen plans, implements, and documents self-hosted open-source platforms in your own infrastructure, and it can prepare the communication channels, wiki pages, version history, and evidence packs that CC2.3 relies on. Work is usually fixed-scope, with scope, deliverables, and timelines agreed in writing before it starts, and ongoing support is available separately as a retainer. DeployOpen does not issue SOC 2 reports, attestations, or opinions. Only an independent CPA firm performing the examination issues the report, and the organization itself owns its controls and the decisions about what it communicates. Ask any partner to confirm this split in writing, and ask your CPA firm which evidence it will sample so the preparation matches what the auditor will test.
A practical test is to draft the list of external communications your organization makes today and mark each one as owned, documented, or undocumented. If most entries are undocumented and no single person can name the owner, bring in help for the design work and keep ongoing ownership in-house. If the list is mostly documented and the gap is evidence, a narrower engagement may be enough. Request a written quote that lists which communication channels, documents, and evidence artifacts are in scope, who approves them, and what is excluded, such as legal review of customer contracts. Confirm with your auditor and legal counsel which external notices they expect to see before you finalize scope, because the answer determines how much design work the partner must cover.
How DeployOpen prepares CC2.3 evidence
The sequence below shows how DeployOpen scopes the external communication work, builds the self-hosted channels and records it depends on, and hands the auditor evidence that a CPA firm can test. DeployOpen prepares these systems and records only; the independent CPA firm performs the examination and issues the report.
Agree the communication scope in writing
Before work starts, DeployOpen and the client agree in writing which external parties matter for CC2.3: customers, vendors, regulators, the board and any other groups that rely on the service. The scope names the commitments, notices and inbound channels in use, and states which privacy-related points of focus apply if the privacy category is in scope. The client owns the control design; DeployOpen confirms the scope document matches what the systems will do. The output is a signed scope document that the CPA firm can review.
Map existing external communications
DeployOpen inventories how the client already talks to outside parties: status pages, security contact addresses, customer notices, contract change procedures, vendor escalation paths and regulator correspondence. Gaps are recorded against the agreed scope, such as a missing inbound security address or no defined route to the board. The client decides which gaps to close. The output is a gap list tied to each communication channel and its owner.
Set up self-hosted channels in client infrastructure
Where the client wants platform-hosted communication records, DeployOpen deploys and configures the chosen open-source tools inside the client's own cloud accounts, data centers or air-gapped networks. Inbound security and privacy contact routes are set up with defined owners, and a separate reporting line can be created for sensitive matters. Access to these tools follows the client's identity controls. The output is a tested, documented channel configuration that the client has accepted.
Configure versioned records for notices and changes
DeployOpen configures a self-hosted wiki or documentation platform to hold customer-facing notices, system change summaries, incident communication templates and the external contact register. XWiki keeps version history recording what changed, when and by whom, and BookStack permissions can be set per role at shelf, book, chapter or page level. Editing and approval rights are set so only named owners can publish. The output is a configured record system with role assignments and a test showing version comparison and rollback work.
Document procedures and approval steps
DeployOpen writes or refines the procedures the client's staff follow: who drafts a customer notice, who approves it, how a system change is communicated before it takes effect, how an incident update reaches affected parties, and how inbound questions are logged and answered. The client's leadership reviews and adopts the procedures. The output is an approved procedure set with named roles, linked to the scope document and the channel configuration.
Collect and index evidence for the auditor
DeployOpen gathers the records that show communication happened as designed: sample customer notices, change announcements, inbound request logs, board communication minutes, vendor notices and version histories. Each item is indexed to the CC2.3 points of focus in scope and labeled with date, owner and approver. Gaps found during collection go back to the client for remediation. The output is an evidence binder the client reviews and gives to the CPA firm, which decides what to test and how.
Run a readiness review before fieldwork
DeployOpen walks through the evidence index with the client's compliance lead, checking that each record can be retrieved and that the procedures match what staff actually do. Discrepancies are fixed or documented as exceptions for management to explain. The client shares the readiness outcome with the CPA firm during planning. This review does not replace the auditor's testing. The output is a signed readiness checklist and a list of open items with owners.
Maintain the evidence with a retainer
Communication channels, notice templates and contact registers change as products and vendors change. DeployOpen can continue to support the self-hosted tools, upgrade them, review the evidence index and refresh procedures under an ongoing retainer, with the scope and cost agreed in writing. The client remains responsible for its controls and for every communication sent. DeployOpen does not issue reports, attestations or certifications; only the independent CPA firm does. The output is a maintained evidence set ready for each examination period.
