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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.

  1. SOP-01

    Client data handling and least-privilege access

    operating

    Client 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

  2. SOP-02

    Secrets management

    in progress

    Secrets 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

  3. SOP-03

    Development, test / production separation

    operating

    Development 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

  4. SOP-04

    Tenant isolation

    operating

    Each 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

  5. SOP-05

    Logging and monitoring

    operating

    Security-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

  6. SOP-06

    Encryption in transit and at rest

    operating

    Data 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

  7. SOP-07

    Access provisioning and deprovisioning

    operating

    Access 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

  8. SOP-08

    Backup and recovery

    operating

    Backups 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

  9. SOP-09

    Data retention and deletion

    operating

    Client 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

  10. SOP-10

    Incident response and breach reporting

    operating

    Incidents 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

  11. SOP-11

    Processing integrity

    operating

    Data 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

  12. SOP-12

    Change management

    in progress

    Changes 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.