SOC 2 Control Implementation Guide

Asset, Data & Architecture

Architecture and Data Flow Documentation for SOC 2

Critical data flows, repositories, integrations, trust boundaries, customer-data processing paths, and AI/LLM data flows are documented and maintained.

Use this guide to put the control into operation, decide what records to retain, and check that an auditor can trace the evidence back to the work your team performed.

Maintained by GreenHat Security · Reviewed August 21, 2026

What this control should accomplish

Engineers, security, and privacy reviewers can follow critical information from collection through processing, storage, integration, and exit, including trust boundaries, customer-data paths, and any AI or language-model processing.

First SOC 2 program

A credible starting point

Create a system-context diagram and a data-flow view for each customer-facing product. Mark production boundaries, major repositories, external integrations, administrative paths, and where customer data enters and leaves; review them with an engineer who operates the service.

As the company scales

Make it repeatable

Maintain diagrams and integration records in a versioned architecture repository, assign them to service owners, and make updates part of architecture and production-change review. Use cloud, API, data-catalog, and infrastructure records to challenge whether the diagrams remain complete.

How to implement Architecture and Data Flow Documentation

  1. 1

    Set system boundaries

    Define the customer-facing services, production environments, supporting platforms, external parties, and administrative interfaces covered by each view.

    You should end up with: A scoped system-context diagram with named boundaries and owner.

  2. 2

    Trace important data flows

    Follow customer data, telemetry, authentication data, support exports, and other critical information from ingress to stores, processors, backups, and egress.

    You should end up with: A data-flow diagram with data categories, direction, and repositories labeled.

  3. 3

    Mark trust and protection points

    Identify network and tenant boundaries, privileged paths, encryption transitions, key dependencies, logging points, and cross-environment movement.

    You should end up with: Annotated diagrams showing trust boundaries and major safeguards.

  4. 4

    Record integrations and AI processing

    Document third-party APIs, subprocessors, support tools, analytics, model providers, retrieval stores, and the data each receives or returns.

    You should end up with: An integration inventory linked to the relevant diagram and data categories.

  5. 5

    Validate against operation

    Have service owners compare diagrams with cloud resources, deployments, configuration, data stores, and current integrations, then resolve discrepancies.

    You should end up with: A dated review record with corrections and owner approval.

  6. 6

    Tie updates to change

    Require architecture and data-flow impact to be considered for new services, repositories, integrations, and material production changes.

    You should end up with: Change records linking to revised diagrams or documenting no impact.

Evidence to keep, and what it should prove

Build the evidence set in three layers: what defines the control, who approved or reviewed it, and what proves it operated. Collect operating records when the work happens so they remain dated, attributable, correctly scoped, and traceable to the underlying activity.

Before sharing, remove unrelated personal or customer data, never expose passwords, tokens, or secret values, preserve enough source context to authenticate the record, and use the secure exchange approved for the engagement.

Policy / design artifacts

Documents that define the control, its scope, ownership, and expected way of working.

Architecture diagrams

  • Confirm what the record proves

    Shows the current service components, environments, external dependencies, administrative paths, and trust boundaries that make up the scoped system.

  • Include this context

    service and environment scope

  • Include this context

    components and repositories

  • Include this context

    external dependencies

  • Include this context

    trust boundaries

  • Include this context

    owner

  • Include this context

    version or review date

Weak evidence to avoid

An undated sales architecture picture with product logos but no environments, data stores, trust boundaries, owner, or revision history.

data flow diagrams

  • Confirm what the record proves

    Shows how named customer and sensitive data categories move from collection through processing, storage, integration, backup, and exit.

  • Include this context

    data category

  • Include this context

    source and destination

  • Include this context

    flow direction

  • Include this context

    repository or processor

  • Include this context

    trust-boundary crossing

  • Include this context

    version or review date

Weak evidence to avoid

Arrows between services with no data categories, direction, third parties, backup path, or customer-data distinction.

integration inventories

  • Confirm what the record proves

    Shows the active internal and third-party connections, their owners, the data exchanged, and whether model, analytics, support, or subprocessor paths are represented.

  • Include this context

    integration and owner

  • Include this context

    source and destination systems

  • Include this context

    data categories and direction

  • Include this context

    business purpose

  • Include this context

    authentication or transfer method

  • Include this context

    lifecycle status

Weak evidence to avoid

A vendor list that does not identify active interfaces, transferred data, direction, owner, or disabled connections.

Operating / technical evidence

Dated proof that the control actually ran, such as tickets, logs, settings, exports, reports, and test results.

change records

  • Confirm what the record proves

    Shows that material service, repository, integration, or data-use changes were checked for architecture and data-flow impact and caused updates where needed.

  • Include this context

    change identifier and date

  • Include this context

    affected service or data path

  • Include this context

    impact decision

  • Include this context

    reviewer

  • Include this context

    diagram or inventory revision

  • Include this context

    deployment status

Weak evidence to avoid

A deployment ticket that names code changes but contains no architecture impact decision or link to revised documentation.

Which records should you prepare for the audit?

Type 1

Evidence at the as-of date

The current approved architecture views, data-flow diagrams, and active integration inventory for every scoped customer-facing service on the examination date, including known documentation gaps.

Type 2

Evidence across the review period

Every production change during the review period that added or materially changed a service, repository, integration, trust boundary, customer-data path, or model-processing path, plus every scheduled quarterly production documentation review and annual supporting-system review.

Completeness check

Compare period production deployments, cloud resource additions, API registrations, integration enablements, and data-catalog changes with architecture-impact decisions; then map every active scoped service and integration to a current owned diagram and investigate unmatched changes or components.

Build the record set from

  • architecture repository
  • production change system
  • cloud and service inventory
  • API or integration catalog
  • data catalog
  • code and infrastructure repositories

Keep these fields for each record

  • service and environment
  • change or review identifier
  • effective or deployment date
  • affected component or data flow
  • integration and data categories
  • impact decision
  • document revision
  • owner and reviewer

How an auditor may test this control

Use this checklist to prepare for procedures an auditor may perform. The exact steps and sample selection depend on your engagement scope and the service auditor's professional judgment.

  • Confirm the intended control outcome

    Determine whether the control is designed to achieve this result: Engineers, security, and privacy reviewers can follow critical information from collection through processing, storage, integration, and exit, including trust boundaries, customer-data paths, and any AI or language-model processing.

  • Confirm ownership and operating cadence

    Compare the documented owner with the intended role (Engineering / Infrastructure / Data Owner), then compare dated records with the stated cadence: Quarterly for production/customer-impacting; annually for supporting assets.

  • Establish the complete audit record set

    Compare period production deployments, cloud resource additions, API registrations, integration enablements, and data-catalog changes with architecture-impact decisions; then map every active scoped service and integration to a current owned diagram and investigate unmatched changes or components.

  • Prepare the as-of-date evidence for a Type 1 engagement

    The current approved architecture views, data-flow diagrams, and active integration inventory for every scoped customer-facing service on the examination date, including known documentation gaps.

  • Prepare period evidence for a Type 2 engagement

    Every production change during the review period that added or materially changed a service, repository, integration, trust boundary, customer-data path, or model-processing path, plus every scheduled quarterly production documentation review and annual supporting-system review.

  • Inspect the policy / design artifacts

    Documents that define the control, its scope, ownership, and expected way of working.

    • Inspect Architecture diagrams

      For each selected record, confirm it demonstrates Shows the current service components, environments, external dependencies, administrative paths, and trust boundaries that make up the scoped system.

      • service and environment scope
      • components and repositories
      • external dependencies
      • trust boundaries
      • owner
      • version or review date
    • Inspect data flow diagrams

      For each selected record, confirm it demonstrates Shows how named customer and sensitive data categories move from collection through processing, storage, integration, backup, and exit.

      • data category
      • source and destination
      • flow direction
      • repository or processor
      • trust-boundary crossing
      • version or review date
    • Inspect integration inventories

      For each selected record, confirm it demonstrates Shows the active internal and third-party connections, their owners, the data exchanged, and whether model, analytics, support, or subprocessor paths are represented.

      • integration and owner
      • source and destination systems
      • data categories and direction
      • business purpose
      • authentication or transfer method
      • lifecycle status
  • Inspect the operating / technical evidence

    Dated proof that the control actually ran, such as tickets, logs, settings, exports, reports, and test results.

    • Inspect change records

      For each selected record, confirm it demonstrates Shows that material service, repository, integration, or data-use changes were checked for architecture and data-flow impact and caused updates where needed.

      • change identifier and date
      • affected service or data path
      • impact decision
      • reviewer
      • diagram or inventory revision
      • deployment status
  • Trace the control from design to operation

    Use the categories that apply to this control: connect any policy or design artifact to its approval or review record, then trace a selected operating record through execution, result, and any exception or remediation.

Common implementation and evidence gaps

  • A polished architecture picture shows components but not what data moves between them.
  • Support exports, logs, analytics, backups, and administrative paths are missing.
  • External integrations are named without the data shared or direction of transfer.
  • AI features show the model call but omit prompts, retrieval stores, outputs, or provider retention behavior.
  • Diagrams have no owner, version, review date, or connection to the change process.
  • The documented trust boundary does not match current cloud accounts, networks, or tenant separation.

Before you call this control ready

  • Can a reviewer trace one customer record from collection through every store, processor, backup, and exit?
  • Do live cloud resources and integration settings agree with the current diagrams?
  • Are customer-data paths, trust boundaries, and administrative access visibly distinguished?
  • Are model providers, retrieval data, analytics, support tools, and subprocessors represented where applicable?
  • Did recent material changes either update the diagrams or record a justified no-impact conclusion?

Trust Services Criteria references

These identifiers help you navigate related Trust Services Criteria. They do not reproduce the criteria or prove that this control fully addresses them in your environment.

  • CC2.1
  • CC3.2
  • CC5.2
  • C1.1
  • P4.1

Confirm final scope, mappings, and testing expectations with your service auditor. SOC 2® is an AICPA trademark; GreenHat Security is not affiliated with or endorsed by AICPA.