How to Collect SOC 2 CC8 Evidence When Changes Are Manual with Screenshots

SOC 2 audits require rigorous evidence for change management (CC8), often involving screenshots of manual processes and application-level configurations. While many compliance tools automate infrastructure checks via GitHub or GitLab, manual changes to SaaS platforms, internal admin panels, and database configurations often remain a documentation burden. AI-driven automation now allows teams to capture these manual workflows, validate the evidence, and generate audit-ready reports automatically, closing the gap between manual work and automated compliance.

What Is SOC 2 CC8 Evidence for Manual Changes?

In a SOC 2 (System and Organization Controls 2) audit, the CC8 series (Change Management) focuses on how an organization manages changes to its systems, applications, and infrastructure. Specifically, CC8.1 requires that the "entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes" to meet its objectives.

For many modern SaaS companies, changes aren't always code-based. They include:

Updating permissions in a production admin dashboard.
Changing security configurations in a SaaS tool (e.g., Salesforce, HubSpot).
Manual database updates performed via a GUI.
Emergency hotfixes that bypass standard CI/CD pipelines.

Because these changes do not leave a "trail" in a code repository like GitHub, auditors require manual evidence—usually in the form of timestamped screenshots—to prove that the change was requested, tested, approved, and implemented correctly.

How Do I Document Change Management Without a CI/CD Pipeline?

When changes are manual, you cannot rely on automated API integrations from GRC (Governance, Risk, and Compliance) platforms like Drata or Vanta to pull "Pull Request" data. Instead, you must build a manual evidence pack that follows the lifecycle of the change.

The Four Pillars of Manual CC8 Evidence:

The Request: Evidence of why the change was needed (e.g., a ticket or email).
The Approval: Visual proof that a qualified individual (other than the person making the change) authorized the action.
The Testing: Screenshots showing that the change was verified in a staging or sandbox environment before moving to production.
The Implementation: Proof of the final state in the production environment, including timestamps and the identity of the person who performed the action.

Traditionally, this process takes 2–4 hours of manual effort per change to document. With compliance evidence automation, an AI agent records the person performing these steps and automatically extracts the necessary screenshots and metadata into a structured PDF.

Where Traditional SOC 2 Automation Stops for Change Management

Most compliance automation platforms are "API-first." They excel at monitoring what they can "see" through an integration. However, they hit a wall when it comes to the user interface (UI) of your proprietary application or third-party SaaS tools.

Feature	Traditional GRC Tools (Drata/Vanta)	Screenata Evidence Automation
Code Changes (GitHub/GitLab)	Fully Automated	Supported via Workflow Capture
SaaS Config Changes	API-Dependent (Often Limited)	Fully Automated (UI Recording)
Internal Admin Panels	No Visibility	Full Visibility (Computer Vision)
Manual UI Testing	Requires Manual Screenshots	AI-Agent Generated Screenshots
Evidence Format	Folder of Images	Structured, Audit-Ready PDF Pack

The Gap: If you change a security setting in an internal tool that doesn't have a robust API, Drata or Vanta will flag that control as "manual." You are then forced to manually capture screenshots, write a narrative, and upload the file. This is the "20% manual gap" that leads to audit fatigue.

Do Auditors Accept AI-Generated SOC 2 CC8 Evidence?

Yes. Auditors accept AI-generated evidence as long as it meets the criteria of being sufficient, reliable, and relevant. The AICPA (American Institute of Certified Public Accountants) does not mandate how evidence is collected, only that it accurately represents the control's operation.

For manual CC8 evidence to be reliable, it must include:

Authenticity: Proof that the screenshots haven't been tampered with (cryptographic hashing).
Context: A clear narrative of what the screenshot represents.
Timestamps: Precise data showing when the change occurred.
User Attribution: Clear identification of who performed the test and who approved it.

AI tools like Screenata enhance this reliability by providing a verifiable metadata chain. Instead of a loose PNG file, the auditor receives a PDF that includes DOM snapshots, browser logs, and NTP-synced timestamps, making the evidence more trustworthy than a standard manual screenshot.

Step-by-Step: Automating Manual Change Evidence with Screenata

If you are performing a manual configuration change and need to satisfy CC8.1, follow this automated workflow:

Step 1: Launch the Evidence Capture Agent

Before starting the change, open the Screenata browser extension. Select the relevant SOC 2 control (e.g., CC8.1 – Change Management).

Step 2: Record the Workflow

Perform the change as you normally would.

Show the Approval Ticket (e.g., in Jira or Slack).
Show the Testing Phase in your staging environment.
Navigate to the Production Environment and implement the change.
Show the Final Configuration state.

Step 3: AI-Powered Evidence Generation

The AI agent analyzes the recording in real-time. It identifies key moments—like clicking the "Save" button or the "Approved" status on a ticket—and captures high-resolution screenshots. It then uses OCR (Optical Character Recognition) to extract text and write a narrative description for each step.

Step 4: Redaction and Validation

The system automatically blurs any PII (Personally Identifiable Information) or sensitive keys discovered during the recording. You review the generated Evidence Pack, ensure it captures the intent of the control, and hit "Finalize."

Step 5: Sync to Your GRC Platform

The structured PDF and ZIP pack are automatically pushed to your compliance dashboard (Drata, Vanta, etc.), marking the manual evidence task as "Complete" for the auditor.

Comparison: Manual vs. Automated Evidence for CC8

Metric	Manual Screenshotting	Screenata Automation
Preparation Time	60–120 minutes	5 minutes
Risk of Human Error	High (Missing timestamps/context)	Low (Machine-standardized)
Auditor Review Time	Slow (Unstructured files)	Fast (Structured PDF packs)
Data Privacy	Manual blurring required	Automated AI redaction
Traceability	Limited to file metadata	Full cryptographic chain of custody

Why Manual CC8 Evidence is the #1 Reason for SOC 2 Delays

Many organizations underestimate the volume of manual changes that occur outside of their primary code repository. During a SOC 2 Type II audit, which covers a 3-to-12 month window, an auditor may ask for a sample of 10–25 changes.

If those changes were manual and you didn't document them at the time they happened, you are forced to "re-perform" the evidence collection. However, you cannot re-perform a change that has already been implemented. This leads to qualified opinions or "exceptions" in your SOC 2 report, which can damage trust with enterprise customers.

Continuous Evidence Collection ensures that every manual change is documented the moment it occurs, eliminating the "audit crunch" at the end of the observation period.

Frequently Asked Questions

What constitutes "manual" change in SOC 2?

A manual change is any modification to the production environment that does not go through an automated deployment pipeline. This includes UI-based configuration changes in SaaS tools, manual database queries, and changes to internal admin settings.

How does Screenata handle sensitive data in screenshots?

Screenata uses on-device AI to detect and redact sensitive information like passwords, credit card numbers, and PII before the evidence is stored. This ensures you satisfy your audit without violating privacy laws like GDPR or HIPAA.

Can I use Screenata if I already use Drata or Vanta?

Yes. Screenata is designed to complement Drata and Vanta. While those tools monitor your infrastructure via API, Screenata acts as the "visual sensor" for the manual application-level tasks that those platforms cannot automate.

Does CC8.1 require screenshots for every change?

Not necessarily, but for manual changes where no system logs exist, screenshots are the most effective way to prove to an auditor that the change followed your internal policies.

Key Takeaways

✅ Manual changes need visual proof: SOC 2 CC8.1 requires evidence of authorization, testing, and approval for all changes, even those not in GitHub.
✅ Automation closes the 20% gap: AI agents can record manual workflows and generate audit-ready evidence packs in minutes, not hours.
✅ Auditors prefer structured data: Standardized PDFs with timestamps and metadata are more reliable and easier to review than folders of random screenshots.
✅ Integration is essential: Automated evidence should sync directly with your GRC platform (Drata/Vanta) to maintain a single source of truth.
✅ Proactive collection prevents audit failure: Documenting manual changes as they happen avoids the risk of missing evidence during the audit window.

Learn More About SOC 2 Automation

For a complete guide to automating SOC 2 evidence collection, including how to collect CC8 evidence for manual change management processes, see our comprehensive SOC 2 automation guide.