What Counts as Rescreening Evidence for SOC Auditors

Auditors do not want perfection. They want to see that you designed a control on purpose, that you run it as described, and that you can show your work without a week of file-hunting. The strongest rescreening programmes share one trait: evidence that is boringly consistent. Below, I unpack what "good" looks like through the lens of a reviewer, and how to package proof so your next SOC review feels routine, not theatrical.

Approvals: The Origin Story of Your Control

Every credible story starts with a decision. A reviewer's first question is simple: who approved this, and when will you look at it again? Screenshots of a policy PDF are not enough. They are looking for a short paper trail that links intent to operation.

In practice, that means a dated record of who signed the policy, who approved the tier and cadence model, and why the chosen ranges are proportionate to access and impact. The best teams attach the actual matrix alongside a one-line rationale and a "review by" date. The riskiest pattern is an email thread where someone wrote "looks fine" two years ago and no one touched it since. If you cannot show renewal discipline, reviewers will assume the rest of the programme drifts too.

What good approvals look like:

Employee Rescreening Policy v2.3
Approved by: Jane Chen, CISO
Date: March 15, 2024
Next review: March 15, 2025
Rationale: Updated cadence from 24 to 18 months for privileged
access roles following Q4 risk assessment.


Run Logs: Proof That the Engine Turns

Policies set direction. Logs prove motion. A clean run log reads like a flight manifest: one row per person per cycle, consistent fields, no gaps around sensitive roles. Reviewers scan for three things. First, completeness. Are the high-risk names all present for the period in scope? Second, recency. Do the "completed" dates align with your stated cadence? Third, control of the future. Is "next due" populated, or are you flying on hope?

Teams that impress here do something unfashionable: they keep it simple. They resist bespoke columns by department. They lock headers. They record outcomes as pass or flag, and push raw detail behind a permissioned door. The result is a log that can be read in minutes and defended in seconds.

Strong run log example:

Employee ID: EMP001 | Risk Tier: High | Last Screen: Jan 15, 2024
Status: Complete | Next Due: Jan 15, 2025 | Exception: None | Owner: HR

Employee ID: EMP002 | Risk Tier: Medium | Last Screen: Jun 10, 2023
Status: Exception | Next Due: Jun 10, 2024 | Exception: Visa pending | Owner: J.Smith


What reviewers love: no missing high-risk roles, consistent formats, future dates populated. What triggers findings: gaps in coverage, misaligned completion dates, empty "next due" fields.

Exception Management: Discipline Beats Bravado

Every programme has exceptions. Reviewers are not offended by that. What worries them is an exception with no owner, no expiry and no compensating control. If a certificate is delayed because a hire moved countries, say so. Limit production access. Set a date to revisit. Name the risk owner who accepts the residual risk. When you show this discipline, an exception becomes evidence of control, not a confession of failure.

A useful rule of thumb is that exceptions live for a maximum of twelve months, and high-risk exceptions should be shorter. If you often exceed these windows, the problem is not evidence. It is design.

Strong exception example:

Exception ID: EXC-2024-015
Employee: [Redacted] - Senior Database Administrator  
Issue: Background check delayed - candidate relocated from India
Compensating controls: Read-only access, daily log review
Target resolution: April 30, 2024
Risk owner: Database Operations Manager


The Evidence Pack Index: A One-Page Map That Saves Everyone's Time

You can halve the back-and-forth of most audits with a single page. Call it an evidence pack index. It tells reviewers what they will see, where it lives, and who owns it. It lists the policy version, the cadence model, the run log extract for the sampled period, the live exception register and the approvals bundle. It also explains, in one sentence each, how personal data has been minimised and how to request unredacted views if strictly necessary.

This index turns a pile of files into a coherent story. It also signals confidence. You are saying, in effect, "We have done this before. Here is how it works."

Sample index structure:

SOC 2 Evidence Pack - Employee Rescreening
Period: January 1 - December 31, 2024
Contact: Sarah Johnson, Compliance Manager

CONTENTS:
1. Employee_Rescreening_Policy_v2.3.pdf
2. Risk_Tier_Matrix_2024.pdf
3. Run_Log_Extract_2024_REDACTED.xlsx
4. Exception_Register_2024_REDACTED.pdf
5. Policy_Approval_Bundle_2024.pdf

DATA HANDLING:
- Personal identifiers redacted using [XXX] format
- Full unredacted views available upon request
- Password protected, 30-day expiry link


Export Routine: Make Redaction the Default

Nothing undermines trust faster than shipping raw personal data when a pass or flag would do. Mature teams standardise their export routine. They agree the sample window and roles up front. They duplicate the working log, redact sensitive fields, export approvals and policy as PDFs, and bundle everything with the index and a short readme. Delivery is via a secure, time-limited link. There is a record of what was shared and to whom.

This is not theatre. It is the line between "We can get that to you by tomorrow" and "Can we have another week, the person with the spreadsheet is on leave".

Standard export checklist:

• [ ] Create working copy of master run log
• [ ] Replace names with employee IDs (EMP001, EMP002...)
• [ ] Redact personal information, preserve operational data
• [ ] Convert documents to PDF for consistency
• [ ] Bundle with password protection and secure sharing
• [ ] Log distribution in audit trail

Red Flags That Trigger Findings

There are patterns that almost always earn a note in the report. "Periodic" cadence with no ranges or triggers. Missing entries for high-risk roles in the sampled quarter. Open-ended exceptions. Inconsistent columns by team. Evidence hunts that stretch beyond a day. Exports containing unnecessary personal data. Vendor staff with system access but no log entries. Each of these is avoidable. Each of these reads, to a reviewer, as a design problem disguised as paperwork.

Common red flags:

• Vague policy language ("checks performed periodically")
• Missing operational evidence for audit period
• Exceptions with no expiry dates or compensating controls
• Different spreadsheet formats by department
• Raw personal data in evidence exports
• Long delays in producing requested documentation

What "Good" Looks Like in the Room

When evidence lands well, the review changes tone. You show approvals with renewal dates and rationale. You present a tidy run log where the most sensitive names are the least surprising. You point to exceptions that tell a story of control, not convenience. You hand over a single zip with an index that matches your verbal walkthrough. Questions become specific, not existential. Time that would have been spent reconciling columns is spent confirming understanding.

That is the point. Evidence is not decoration for an audit. It is the operating system of trust.

If you are building this from scratch, start with three moves. Standardise the run log. Stand up a single exception register with mandatory expiry and controls. Write the one-page index and commit to redaction by default. Once those are in place, approvals history and a formal export routine are quick wins, not rescue missions.

Building robust evidence practices takes time, but the investment pays dividends in smoother audits and stronger security posture. If you're looking to implement or improve your rescreening evidence management, reach out to our sales team to set up a chat about your specific requirements.

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