Migrating from SOC 2 to GDPR
SOC 2 provides a strong security foundation, but GDPR is fundamentally different—it's a legal regulation focused on individual privacy rights, not a voluntary security standard. While encryption, access controls, and incident response overlap, you'll need to add legal documentation, data subject rights processes, and privacy-by-design architecture.
Critical Compliance Gaps
Legal Basis for Processing
GDPR requires documented legal basis (consent, contract, legitimate interest, etc.) for every data processing activity. SOC 2 doesn't address the legality of data processing.
Data Subject Rights
GDPR grants individuals rights to access, rectify, erase (right to be forgotten), port their data, and object to processing. SOC 2 has no equivalent requirements.
Data Protection Officer (DPO)
Organizations processing large amounts of personal data must appoint a DPO. This role doesn't exist in SOC 2 requirements.
72-Hour Breach Notification
GDPR requires notifying supervisory authorities within 72 hours of discovering a personal data breach. SOC 2 has no specific timeline.
Privacy by Design
GDPR mandates data protection by design and by default in all systems and processes. SOC 2 focuses on security controls without this privacy-first architecture requirement.
Step-by-Step Migration Roadmap
Follow these 12 steps to achieve GDPR compliance. Estimated timeline: 14 weeks.
Map SOC 2 controls to GDPR Articles 24, 25, 28, 30, and 32
Create Records of Processing Activities (ROPA) per Article 30
Document legal basis for each data processing activity
Implement Data Subject Rights request handling procedures
Assess need for Data Protection Officer appointment
Update privacy notices to GDPR standards
Implement 72-hour breach notification procedures
Review and update Data Processing Agreements with vendors
Conduct Data Protection Impact Assessments (DPIAs) where required
Implement privacy by design in development processes
Train staff on GDPR-specific requirements
Establish cross-border data transfer mechanisms (SCCs, adequacy decisions)
Unique GDPR Requirements
Strategic Use Cases
Verification Sources
Last verified: January 12, 2026
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SOC 2 to GDPR Migration FAQs
Does SOC 2 compliance mean I'm GDPR compliant$2
No. SOC 2 and GDPR serve different purposes. SOC 2 demonstrates security controls to business customers; GDPR is a legal requirement protecting individual privacy rights. However, SOC 2's security controls support GDPR Article 32 requirements.
Do I need GDPR if I'm a US company$3
Yes, if you process personal data of EU residents. GDPR applies based on whose data you process, not where your company is located. Most SaaS companies serving global customers need GDPR compliance.
What are the penalties for GDPR non-compliance$4
Fines can reach up to €20 million or 4% of global annual turnover, whichever is higher. Even small violations can result in significant fines—regulators have issued penalties ranging from thousands to billions of euros.
How long does GDPR compliance take after SOC 2$5
Typically 3-4 months. The work is primarily legal and procedural—documenting legal basis, implementing data subject rights, and creating privacy notices—rather than technical security controls.
About RiscLens
Our mission is to provide transparency and clarity to early-stage technology companies navigating the complexities of SOC 2 (System and Organization Controls 2) compliance.
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Built specifically for early-stage and growing technology companies—SaaS, fintech, and healthcare tech—preparing for their first SOC 2 audit or responding to enterprise customer requirements.
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Our Boundaries
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SOC 2 (System and Organization Controls 2) is a voluntary compliance standard for service organizations, developed by the AICPA, which specifies how organizations should manage customer data based on the Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy.
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