Trust / SOC 2 posture
SOC 2 posture
Phase Transitions holds no SOC 2 report and no ISO 27001 certificate. Its controls are self-assessed: twelve operating procedures built against the SOC 2 Trust Services Criteria and ISO/IEC 27001 Annex A, a signed policy set, a quarterly evidence cycle, and a first internal audit. This page states each of them with its status and dates. It is regenerated from the practice's own registers; figures are as at 18 September 2026.
Where the practice stands
- Basis
- Self-assessed against the SOC 2 Trust Services Criteria (2017) and mapped to ISO/IEC 27001 Annex A. No auditor has examined the controls.
- Operating procedures
- 12: 10 operating, 2 in progress.
- Policy set
- 22 controlled documents, signed by the director on 31 August 2026 and reviewed annually under a document-control procedure.
- Evidence
- First quarterly cycle run in August 2026: access review, deletion drill, incident-response tabletop, endpoint verification, restore drill, patch triage. First internal audit 28 August 2026.
- Independent assurance
- None. No SOC 2 report, no ISO 27001 certificate, no external penetration test.
- Scope
- Phase Transitions (Pty) Ltd and both platforms it operates: the accounting analytics platform and WealthVault.
Operating procedures
Each procedure is written as one commitment in standard control language, with the SOC 2 criteria and Annex A controls it is built against. A procedure is marked operating only when it is true and evidenced. Each has a written test, mechanical where possible.
- SOP-01
Client data handling and least-privilege access
operatingClient production data lives only in managed cloud infrastructure under least-privilege access: it never lands at rest on personal or developer devices, and every access is logged.
SOC 2 c2.1, cc5.2, cc6.1, ddq.data-residency, ddq.tenant-isolation-multitenancy · ISO 27001 A.5.14, A.8.2, A.8.12
- SOP-02
Secrets management
in progressSecrets are held in a managed secrets manager (1Password) and never in source control. Production workloads receive them by runtime injection through scoped service accounts. Development uses registered per-project secret files whose values are passed to processes without being displayed, and AI coding agents hold no access to the secrets manager. Secrets are rotated on a schedule and on compromise.
SOC 2 cc6.1, ddq.api-access-control-rbac, ddq.encryption-in-transit-at-rest · ISO 27001 A.5.17, A.8.24
- SOP-03
Development, test / production separation
operatingDevelopment and testing run against synthetic or de-identified data; production data is never used in development.
SOC 2 cc3.4, cc8.1 · ISO 27001 A.8.31, A.8.33
- SOP-04
Tenant isolation
operatingEach client's data is reachable only by that client's scoped identity; cross-client access is denied, and this is proven by an automated test.
SOC 2 cc6.1, ddq.tenant-isolation-multitenancy · ISO 27001 A.5.15, A.8.22
- SOP-05
Logging and monitoring
operatingSecurity-relevant events and AI prompt/output access are logged, and the system is monitored for failures and anomalies.
SOC 2 cc7.2, cc7.3, ddq.prompt-output-logging-audit · ISO 27001 A.8.15, A.8.16
- SOP-06
Encryption in transit and at rest
operatingData is encrypted in transit and at rest by our managed infrastructure providers.
SOC 2 ddq.encryption-in-transit-at-rest · ISO 27001 A.8.24
- SOP-07
Access provisioning and deprovisioning
operatingAccess is granted on a need basis, reviewed periodically, and removed promptly when no longer required.
SOC 2 cc6.2, cc6.3 · ISO 27001 A.5.16, A.5.18
- SOP-08
Backup and recovery
operatingBackups are taken, restoration is drilled, and recovery objectives (RTO/RPO) are measured rather than assumed.
SOC 2 ddq.backup-disaster-recovery · ISO 27001 A.5.30, A.8.13
- SOP-09
Data retention and deletion
operatingClient data is retained and deleted according to a defined, verifiable policy.
SOC 2 cc2.5, ddq.data-retention-deletion · ISO 27001 A.5.14, A.8.10
- SOP-10
Incident response and breach reporting
operatingIncidents are detected, contained per a runbook, and reported within the applicable regulatory clocks.
SOC 2 cc7.3, p7.1 · ISO 27001 A.5.24, A.5.26, A.5.28
- SOP-11
Processing integrity
operatingData transformations are predefined, controlled and verified, and the AI reads finished figures: it never authors them.
SOC 2 pi1.1, pi1.4, pi3.2 · ISO 27001 A.8.29
- SOP-12
Change management
in progressChanges are reviewed, tested, and deployed through a controlled path with a known rollback.
SOC 2 cc8.1 · ISO 27001 A.8.32
Criteria index
The same mapping read from the standard's side: each criterion cited above, and the procedures built against it. Items prefixed ddq are vendor due-diligence questions the practice tracks alongside the Trust Services Criteria.
| Criterion | Title | Procedures |
|---|---|---|
| c2.1 | Confidentiality: Internal Access Restrictions | SOP-01 |
| cc2.5 | Disposes of Information to Meet Confidentiality, Availability, and Privacy Objectives | SOP-09 |
| cc3.4 | Identifies Significant Changes Impacting Controls | SOP-03 |
| cc5.2 | Protects Information Assets to Enable Authorized and Prevent Unauthorized Access | SOP-01 |
| cc6.1 | Restricts System and Network Access via Logical and Physical Rules | SOP-01, SOP-02, SOP-04 |
| cc6.2 | Registers and Authorizes New Users Before Issuing Credentials | SOP-07 |
| cc6.3 | Authorizes, Modifies, Disables, and Removes Access Timely | SOP-07 |
| cc7.2 | Monitors System Components for Anomalies | SOP-05 |
| cc7.3 | Raises and Escalates Anomalies to Appropriate Personnel | SOP-05, SOP-10 |
| cc8.1 | Plans, Builds, and Configures New System Components Before Use | SOP-03, SOP-12 |
| ddq.api-access-control-rbac | API Access Control and Role-Based Permissions | SOP-02 |
| ddq.backup-disaster-recovery | Backup and Disaster Recovery | SOP-08 |
| ddq.data-residency | Data Residency and Cross-Border Transfer | SOP-01 |
| ddq.data-retention-deletion | Data Retention and Deletion: Timeframe and Verification | SOP-09 |
| ddq.encryption-in-transit-at-rest | Encryption in Transit and at Rest | SOP-02, SOP-06 |
| ddq.prompt-output-logging-audit | Prompt and Output Logging for Audit | SOP-05 |
| ddq.tenant-isolation-multitenancy | Tenant Isolation and Multitenancy Security | SOP-01, SOP-04 |
| p7.1 | Privacy: Incident Monitoring and Personal-Data Breach Reporting | SOP-10 |
| pi1.1 | Process Automation: Data Input Accuracy | SOP-11 |
| pi1.4 | Process Automation: Authorization of Transactions | SOP-11 |
| pi3.2 | Defined Processes: Release of Output Data | SOP-11 |
Policies and procedures
Every document is numbered one-sentence statements, each with the record that evidences it. Documents are versioned, reviewed annually, and signed by the director; the controlled copy is the source in version control. The set was adopted at its current versions on 31 August 2026.
| PRO-000 | Document control procedure |
| POL-001 | Information security policy |
| POL-002 | Acceptable use policy |
| POL-003 | Anti-malware policy |
| POL-004 | Business conduct policy |
| POL-005 | Data retention and deletion policy |
| POL-006 | Data storage and resilience policy |
| POL-007 | Information classification policy |
| POL-008 | MCP connector allowlist policy |
| POL-009 | On-call and escalation policy |
| POL-010 | Password and authentication policy |
| POL-011 | Personnel security policy |
| POL-012 | Secure development lifecycle policy |
| POL-013 | Supply-chain security policy |
| POL-014 | Vulnerability and patch management policy |
| POL-015 | AI data-handling policy |
| POL-016 | Development and test data policy |
| POL-017 | Operational risk governance |
| STD-001 | Endpoint security standard |
| PRO-001 | Access review procedure |
| PRO-002 | Internal audit procedure |
| PLN-001 | Business continuity and disaster recovery plan |
7 further platform documents describe WealthVault: its system and tokenisation overview, POPIA position, security-testing posture, sub-processor assurance, monitoring, patch process and patch SLA.
Evidence
Each procedure with a cadence has run at least once, with a dated record. The next run is diarised and a lapsed cadence shows red in the practice's daily operations digest.
| Run | Date | Outcome | Next |
|---|---|---|---|
| Access review, first quarterly cycle | 19 Aug 2026 | Twelve surfaces reviewed; removals actioned the same day. A network-rules review of the WealthVault VPC followed on 2026-08-21. | 19 Nov 2026 |
| Deletion drill, first run | 19 Aug 2026 | A retired database deleted end to end under the runbook and verified gone. | 19 Nov 2026 |
| Incident-response tabletop, first run | 19 Aug 2026 | Three scenarios against the written runbook, on the clock. Thirteen findings; the runbook was amended. | 19 Nov 2026 |
| Endpoint verification, first quarterly run | 8 Aug 2026 | Seven checks on the one device that handles client data. Seven of seven pass after one same-day fix. | 8 Nov 2026 |
| Restore drill | 20 Aug 2026 | Logical restore of a production database into a fresh cluster. Recovery time about 40 seconds; all tables present, row counts exact. | Semi-annual |
| Patch triage record | 26 Aug 2026 | Every dependency alert since July triaged under the written patch SLA. Nineteen fixed, none open. | Per batch, within seven days |
| Internal audit, first run | 28 Aug 2026 | Every statement in the document set read against every other and against a client questionnaire's 185 answers. 154 findings, 140 fixed, the rest ruled or dated. | 28 Aug 2027 |
What we do not have
- No SOC 2 report and no ISO 27001 certificate. The controls are self-assessed and mapped to both standards. No auditor has examined them.
- No independent penetration test. For WealthVault it is a gate on live client data, alongside the responsible party's own sign-offs. For the accounting platform it has not yet been commissioned.
- One-person practice. One developer works with AI assistance. Independent code review by a second person is not in place; the controls are enforced by CI rather than by a second reviewer. A break-glass arrangement for the Information Officer's absence is planned and not yet in place.
- Secrets management, in progress. Production workloads take their secrets from a managed secrets manager by runtime injection, and the code estate scans clean for committed secrets. Consolidating the remaining development-side secret files into the manager is in progress.
- Change management, in progress. Changes go through reviewed pull requests with required CI checks on protected main branches. A post-deploy health check and a written per-service rollback are not yet in place.
- No periodic external vulnerability scan. The written patch SLA is in place and dependency alerts are triaged under it. A recurring external scan of internet-facing surfaces is not yet running.
- Provider-managed encryption keys on the accounting platform. Encryption at rest there is managed by the hosting provider; there are no customer-managed keys. WealthVault's database, backups and token vault sit under customer-managed keys.
For a vendor-onboarding review
If you are clearing Phase Transitions as a vendor, write to graham@phasetransitions.ai. The review pack is the signed policy set, the sub-processor and data-processing-agreement register, the SOC 2 and ISO 27001 control mapping, and the confirmation of insurance, shared under the review's confidentiality terms. Questionnaires such as SIG Lite are answered from the same registers.