It’s 2 a.m., and the team is on a call. A security vulnerability has just been flagged in the production system. Hackers are actively exploiting this flaw worldwide. The pressure is on: the system needs an emergency patch—now. Testing? There’s no time. Waiting for standard approvals? Not an option. But as the team scrambles, the compliance officer steps in: ‘Document every step. This emergency change still needs to meet SOC 2 standards.’
This scenario might sound dramatic, but it’s not uncommon in IT environments. Emergency changes, by their very nature, are high-stakes, high-pressure situations. Without proper management, they can spiral into chaos, introducing risks that jeopardize both the business and its compliance obligations.
In IT environments, managing changes is a delicate balancing act. While many changes are planned and follow well-defined processes, others are unexpected and demand immediate action. These are called emergency changes. For organizations pursuing or maintaining SOC 2 compliance, understanding emergency changes and implementing the proper controls is critical to safeguarding sensitive systems and data.
This blog will explore what emergency changes are, how they differ from standard changes, and what controls you need for compliance with SOC 2.
Standard Change vs Emergency Change
The primary differences between standard changes and emergency changes are in their risk level, urgency, and approval process. Standard changes are typically low-risk, pre-approved, and follow a routine, well-documented process, and emergency changes address critical, time-sensitive issues and commonly require expedited actions and approvals to minimize disruption.
What is an Emergency Change?
An emergency change is an unplanned, high-priority change implemented in response to a critical situation that requires immediate action. These changes are typically introduced to address urgent issues such as major system outages, security vulnerabilities, or any condition that threatens the organization’s operations, data security, or compliance obligations.
Examples of Emergency Changes:
- Security Patching: Applying a patch to address a vulnerability actively being exploited.
- Outage Resolution: Making system modifications to restore critical services after a major outage.
- Incident Mitigation: Blocking malicious traffic by reconfiguring firewalls or updating access rules during an ongoing cyber attack.
What is a Standard Change?
A standard change is a planned and pre-authorized change that follows a well-documented and repeatable process. These changes are low-risk, predictable, and often routine. Since the outcomes of standard changes are well understood, they do not require individual approval each time they are implemented. Standard changes undergo thorough testing and documentation before implementation, and they are typically scheduled in advance to minimize disruption to operations.
SOC 2 Compliance & Emergency Changes
Emergency changes are a necessary reality in IT environments, but they must be handled with care to align with SOC 2 compliance requirements. SOC 2 compliance focuses on demonstrating that systems are designed to protect the security, availability, processing integrity, confidentiality, and privacy of data. Emergency changes, if not properly managed, can introduce significant risks to these trust service criteria.
To remain compliant, organizations must implement robust controls for emergency change management. Here’s how.
- Define Emergency Changes: SOC 2 requires that processes be well-documented. Organizations should clearly define what constitutes an emergency change, so that the label is not misused to bypass standard procedures. The organization should maintain a policy with criteria for categorizing changes as “emergency.”
- Approval Process: Emergency changes may bypass regular change advisory boards, however, they should still require approval from designated authority figures, such as a security officer or senior manager. The organization should establish a team to review and approve emergency changes.
- Document Changes: Thorough documentation is required for SOC 2 compliance even though speed is the priority. Documentation should include the rationale for the change, details of the implementation, and the approval process. The organization should create a standardized post-change review template to capture all relevant details.
- Post-Implementation Reviews: Following the implementation of an emergency change, conduct a review to evaluate its effectiveness, document the outcomes, and identify opportunities for improvement. Mandate post-mortem reviews for all emergency changes to maintain alignment with SOC 2’s accountability requirements.
- Access Controls and Monitoring: Emergency changes frequently involve accessing critical systems with elevated privileges, making it essential to restrict and monitor this access. Utilize role-based access control (RBAC) to limit permissions and enable audit logging to track all activities associated with the change.
- Separation of Duties: SOC 2 emphasizes the segregation of responsibilities to prevent conflicts of interest. Emergency changes should follow this principle where possible. The organization should determine that the individual implementing the change is different from the one approving or testing it.
Best Practices for Managing Emergency Changes
Returning to the 2 a.m. crisis, what separated success from failure wasn’t just technical skill—it was discipline. The team adhered to a process, even under pressure, maintaining compliance while resolving the issue. Here’s what made the difference:
- Defined Roles and Responsibilities: Everyone knew their part in the emergency change process.
- Real-Time Documentation: Critical details were captured during implementation.
- Post-Mortem Evaluation: The team used the experience to refine future responses.
Emergency Change – Key Takeaways
Emergency changes are an inevitable part of managing IT systems, but they require a disciplined approach so they do not jeopardize compliance or security. By implementing robust controls and aligning processes with SOC 2 requirements, organizations can handle emergencies effectively without compromising the trust and reliability of their systems. By combining agility with structured oversight, your organization can tackle critical issues while maintaining compliance and safeguarding its operations.
Need expert guidance on managing emergency changes and maintaining compliance? Linford and Company can help you develop robust change management processes that protect your organization. Contact us today to learn about our many audit services, including SOC 1 audits and SOC 2 audits.
Jessica Kiel joined Linford & Company, LLP in 2023 and she came with over twelve years of experience in internal controls, SOX, controls over Financial Reporting (ICFR), SOC1, SOC 2, Third Party Assurance, and attestations/examinations based on PCAOB or AICPA standards. Jessica began her career with Deloitte in 2011 where she served in a leadership role for the last eight years. Jessica graduated from Southern Illinois University-Carbondale with a Bachelor’s of Science in Accounting and a Masters of Accounting.