SOC 2 Control Implementation Guide

AI / LLM Governance

Retrieval Source and Policy Context Governance for SOC 2

Retrieval sources, embeddings, memory, policy context, and customer context are authorized, versioned, and reviewed for accuracy and confidentiality.

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

Retrieval collections, embeddings, memory, policy context, and customer context use authorized content whose owner, version, access boundary, and review status are known.

First SOC 2 program

A credible starting point

Keep an approved source list for each retrieval workflow, name a content owner, and record when source material was added or reviewed.

As the company scales

Make it repeatable

Automate source ingestion approvals, version indexes with releases, enforce document-level authorization, measure staleness, and schedule owner attestations.

How to implement Retrieval Source and Policy Context Governance

  1. 1

    Inventory retrieval sources

    List repositories, documents, feeds, memory stores, indexes, content owners, data classes, and consuming workflows.

    You should end up with: Retrieval source and consumer inventory

  2. 2

    Authorize ingestion

    Require owner approval and access classification before content is chunked, embedded, indexed, or made available to a workflow.

    You should end up with: Source authorization record

  3. 3

    Version source context

    Record content revision, ingestion run, index version, configuration, and release so an answer can be tied to its context set.

    You should end up with: Reproducible index and release manifest

  4. 4

    Review accuracy and access

    Test stale, withdrawn, conflicting, and restricted content while confirming retrieval respects user and tenant authorization.

    You should end up with: Content quality and access review

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.

Retrieval source inventory

  • Confirm what the record proves

    Every indexed or remembered content source has a known owner, classification, consumer, lifecycle status, and access model.

  • Include this context

    Source or collection ID

  • Include this context

    Content owner

  • Include this context

    Classification

  • Include this context

    Consuming workflows

  • Include this context

    Authorization model

  • Include this context

    Lifecycle status

Weak evidence to avoid

A list of vector index names with no original repositories, owners, data classes, consumers, or status.

Approval / review evidence

Records showing that an accountable person reviewed, approved, challenged, or accepted the work.

authorization records

  • Confirm what the record proves

    The content owner approved ingestion and use for the named workflows, audiences, tenants, and purposes.

  • Include this context

    Source ID

  • Include this context

    Approved workflow

  • Include this context

    Audience or tenant scope

  • Include this context

    Purpose

  • Include this context

    Approver

  • Include this context

    Decision date

Weak evidence to avoid

An approval to 'use docs for AI' without the collection, workflow, user scope, purpose, or approver authority.

review records

  • Confirm what the record proves

    A content owner reviewed accuracy, staleness, access, withdrawn material, and required follow-up for the scoped collection.

  • Include this context

    Review ID and date

  • Include this context

    Collection scope

  • Include this context

    Reviewer

  • Include this context

    Quality and access results

  • Include this context

    Decision

  • Include this context

    Actions and due dates

Weak evidence to avoid

A calendar event named retrieval review without the collection, tests, decision, or remediation.

Operating / technical evidence

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

version history

  • Confirm what the record proves

    The team can identify which content revision, ingestion run, index, and retrieval configuration supported a production workflow version.

  • Include this context

    Source revision

  • Include this context

    Ingestion run ID

  • Include this context

    Index version

  • Include this context

    Workflow version

  • Include this context

    Effective time

  • Include this context

    Change summary

Weak evidence to avoid

An index modified in place with only a current timestamp and no content revision or consuming release.

Which records should you prepare for the audit?

Type 1

Evidence at the as-of date

Retain the current retrieval inventory, authorization, active version manifest, and latest content and access review as of the selected date.

Type 2

Evidence across the review period

List every source addition, removal, material content update, ingestion run, index or memory version release, authorization change, and scheduled review during the period, including failed ingestions and emergency removals.

Completeness check

Reconcile repository and ingestion events to index-version manifests and the source inventory, then verify additions have authorization and removals or access changes propagated to every consuming collection.

Build the record set from

  • Content repository
  • Ingestion pipeline
  • Vector database
  • Retrieval configuration history
  • Access-control service
  • Content review tracker

Keep these fields for each record

  • Source and collection IDs
  • Content revision
  • Ingestion run
  • Index version
  • Owner and authorization
  • Effective timestamp
  • Consuming workflow
  • Result or disposition

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: Retrieval collections, embeddings, memory, policy context, and customer context use authorized content whose owner, version, access boundary, and review status are known.

  • Confirm ownership and operating cadence

    Compare the documented owner with the intended role (AI Workflow Owner / CISO / Engineering), then compare dated records with the stated cadence: Per workflow/change; review at least annually.

  • Establish the complete audit record set

    Reconcile repository and ingestion events to index-version manifests and the source inventory, then verify additions have authorization and removals or access changes propagated to every consuming collection.

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

    Retain the current retrieval inventory, authorization, active version manifest, and latest content and access review as of the selected date.

  • Prepare period evidence for a Type 2 engagement

    List every source addition, removal, material content update, ingestion run, index or memory version release, authorization change, and scheduled review during the period, including failed ingestions and emergency removals.

  • Inspect the policy / design artifacts

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

    • Inspect Retrieval source inventory

      For each selected record, confirm it demonstrates Every indexed or remembered content source has a known owner, classification, consumer, lifecycle status, and access model.

      • Source or collection ID
      • Content owner
      • Classification
      • Consuming workflows
      • Authorization model
      • Lifecycle status
  • Inspect the approval / review evidence

    Records showing that an accountable person reviewed, approved, challenged, or accepted the work.

    • Inspect authorization records

      For each selected record, confirm it demonstrates The content owner approved ingestion and use for the named workflows, audiences, tenants, and purposes.

      • Source ID
      • Approved workflow
      • Audience or tenant scope
      • Purpose
      • Approver
      • Decision date
    • Inspect review records

      For each selected record, confirm it demonstrates A content owner reviewed accuracy, staleness, access, withdrawn material, and required follow-up for the scoped collection.

      • Review ID and date
      • Collection scope
      • Reviewer
      • Quality and access results
      • Decision
      • Actions and due dates
  • Inspect the operating / technical evidence

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

    • Inspect version history

      For each selected record, confirm it demonstrates The team can identify which content revision, ingestion run, index, and retrieval configuration supported a production workflow version.

      • Source revision
      • Ingestion run ID
      • Index version
      • Workflow version
      • Effective time
      • Change summary
  • 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

  • Documents enter the index through a shared folder without owner approval.
  • An index is rebuilt in place, so past output context cannot be reconstructed.
  • Source-system permissions are lost when content moves into the vector store.
  • Memory persists customer context beyond the approved session or purpose.

Before you call this control ready

  • Can each indexed collection be tied to an owner and authorization decision?
  • Can the team identify the context version used for a sampled output?
  • Does removing source access remove retrieval access promptly?
  • Are stale or superseded policy documents detected and removed?

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
  • CC8.1
  • C1.1
  • P7.1

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.