How to make your rescreening stand up in a SOC audit

Most SOC reviews are not derailed by obscure clauses. They stall when teams cannot show that a sensible control exists, runs on schedule, and leaves a tidy trail. For personnel rescreening, reviewers circle four areas: how your policy reads in real life, whether cadence is risk-based, how you handle exceptions, and whether your evidence tells a coherent story. Get those right and the conversation moves quickly.

What reviewers keep asking

The first pass is always a comparison of words to reality. If your policy promises “periodic rescreening,” expect a follow-up on ranges, role tiers and triggers. If the policy lists checks you never run, expect a finding. Reviewers then probe cadence decisions for high-risk roles and ask to see the run log for a sampled quarter. They will scan for missed cycles, how you handled them, and whether exceptions have owners, controls and expiry dates.

Across reviews, four themes come up again and again.

1. Policy versus operation
   Reviewers compare the words in your policy to what you actually do. If the policy says “periodic” without ranges, they will probe cadence. If the policy names checks you never run, they will note the gap.
2. Risk-based cadence
   One-size-fits-all schedules are challenged. Reviewers expect to see role tiers, ranges by tier, and clear triggers for off-cycle checks such as access changes.
3. Exception discipline
   Exceptions are acceptable. Open-ended exceptions are not. Auditors look for a reason, a risk owner, compensating controls and a hard expiry date.
4. Evidence that tells a story
   Evidence should show decision, operation and oversight. In practice: approvals with a review-by date, a clean run log for the sampled period, an exception register, and a small export pack that can be shared without overexposing personal data.

Reviewer questions you should be ready for

• Who approved your tier and cadence model and when will it be reviewed
• How did you decide the frequency for high-risk roles
• Show the run log for the sampled quarter for five named roles
• Explain any missed cycles and show the related exception entries
• What personal data do you retain and for how long
• How do you export evidence to clients without oversharing

The minimum evidence that lands well

You do not need a sprawling archive; you need a small set of artefacts that make sense together.

Approvals (governance)

• Policy approval with version and date
• Tier and cadence approval with one-line rationale and review-by date

Run log (operation)

• One row per person per cycle with Subject, Tier, Checks performed, Completed date, Reviewer, Outcome, Next due

Exception register (control of drift)

• Subject, Reason, Risk owner, Compensating controls, Expiry date, Status, Last reviewed

Evidence pack index (navigation)

• A one-page list of what is in the export, where it lives, who owns it, and a note that exports are redacted to pass or flag

Export routine (consistency)

• A seven-step SOP that covers sample agreement, redaction, bundling, secure delivery and a record of what was shared

In practice, that looks like a dated policy approval and a separate approval for the tier and cadence model with a review-by date. It looks like a single run log with fixed headers, one row per person per cycle, outcomes recorded as pass or flag, and a populated “next due” field. It looks like one exception register across the company rather than local spreadsheets. And it looks like a one-page evidence index that lists what is in the pack, where it lives and who owns it, with a note that external exports are redacted by default.

Where gaps become findings

Three patterns almost always trigger comments. The first is vague cadence. “Periodic” without ranges or off-cycle triggers reads like hope. Replace it with ranges by tier and explicit triggers such as access changes or country moves. The second is incomplete coverage in the most sensitive roles. If high-risk names are missing from the sampled period, no amount of policy prose will help. The third is exception drift. An exception without an owner, controls or an expiry suggests the control is optional.

Other friction is avoidable. Inconsistent log columns by team make reconciliation painful. Export packs that include unnecessary personal data slow reviews and raise new questions. Vendor staff with system access but no entries in your scope look like a blind spot. Each of these is solved by standardising headers, redacting exports to pass or flag, and extending scope to supplier personnel who touch your systems or client data.

Quick wins in the fortnight before an audit

If time is short, focus on changes that signal control without rewriting the programme. Begin with the run log: lock a common header and convert free-text outcomes to pass or flag. Close the loop on exceptions as above. Write a one-page index for the evidence pack and save it alongside the policy, cadence model and approvals. Document a short export routine that assumes redaction, bundles the index and a readme, and delivers via a secure, expiring link. Finally, tune the policy language so it matches reality: remove checks you do not run, state ranges per tier, and add a review-by date.

The outcome you are aiming for

SOC reviewers are looking for intent, proportion and proof. If your policy explains who and how often, if your logs show that the engine turns, if exceptions are owned and time-bound, and if your export pack is predictable and minimal, the personnel-screening part of the review becomes routine. You do not need more paperwork. You need fewer, cleaner artefacts that you can produce on demand.

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