SOC 2 Compliance
- Broad security & privacy controls for SaaS & cloud providers
- Based on AICPA Trust Services Criteria • Applies to private & public sector vendors handling sensitive data
- Demonstrates operational security
- Can serve as a steppingstone but does not meet FedRAMP’s stricter requirements
- Can take 6–12 months; requires an ongoing audit period (3–12 months of operational evidence)
FedRAMP (Federal Risk & Authorization Management Program)
- Standardized security for cloud services used by federal agencies
- Built on NIST controls • Required for vendors serving U.S. federal agencies
- Requires an initial readiness assessment, agency sponsorship, and a full security assessment
- Can take 12–24 months due to rigorous assessment & authorization processes
StateRAMP/GOVRAMP Authorization
- Modeled after FedRAMP but tailored to meet the needs of state & local governments
- Increasingly adopted by states to ensure security compliance
- Timing depends on vendor readiness; mirrors FedRAMP processes but may be streamlined for state-level approval (varies by state)
Election Official Considerations
✓ Authorization vs. Certification – FedRAMP and StateRAMP/GovRAMP are authorizations that require ongoing security monitoring, while SOC 2 is an attestation based on an audit of security controls.
Understanding the difference helps in vendor evaluation.
✓ Cloud vs. On-Premises Solutions – FedRAMP and StateRAMP/GovRAMP apply primarily to cloud-based solutions, while SOC 2 can cover both cloud and on-premises software. Agencies should clarify security expectations based on their deployment model.
✓ Timeline – Achieving security certifications and authorizations is a multi-step process that can take years, depending on the framework. Agencies should account for these timelines when planning procurements, ensuring vendors are already on a compliance path to avoid delays in system deployment or upgrades.
✓ StateRAMP/GovRAMP Emerging as the New Standard – Because it provides a structured approach to assessing cloud security risks for state and local government agencies. Many states are adopting it as a requirement for technology vendors to ensure they meet stringent security standards without duplicating federal processes.
✓ Alignment with NIST Standards – Because NIST 800-53 serves as the foundation for FedRAMP and StateRAMP/GovRAMP, vendors with existing NIST-aligned security programs are often better positioned to achieve compliance.
✓ Ask for Evidence – Vendors should provide SOC 2 reports, FedRAMP authorization packages, or StateRAMP/GovRAMP verification upon request. These documents outline their security posture and compliance status.
✓ Shared Security Model – While vendors implement security controls, agencies are responsible for internal security controls and risk assessments.
✓ Risk-Based Decision Making – If a vendor is not yet fully compliant, assess whether they are on a defined compliance path and committed to meeting security standards in a reasonable timeframe.
✓ Cost of Compliance – Vendors who have achieved FedRAMP or StateRAMP /GovRAMP authorization have invested significantly in security. Agencies should recognize that higher compliance standards may come with increased costs, but also provide stronger protections.
✓ Ongoing Security Responsibilities – Achieving compliance is only the first step. Election officials should partner with vendors committed to continuous monitoring, regular security updates, and proactive risk management.