The Penetration Testing Guide for Compliance and Audits

by Bhushan Shinde on March 8, 2022

A penetration test is a simulated cyberattack against an enterprise’s IT system to identify vulnerabilities that are exploitable which can result in a data breach and financial loss to the organization. Penetration Testing helps the organization and IT leaders identify open vulnerabilities within their environment, leading to an attacker accessing privately-owned networks, systems, and sensitive business information.

Penetration Testing is mandated in various industry-specific regulations especially those related to healthcare, Financial and technical industries. These industry-specific compliance standards include but are not limited to ISO27001, PCI-DSS, HIPAA, GDPR, and many more. In terms of enterprise compliance, Pentest provides assurance for independent assessment of a company’s cybersecurity program and showcases concrete evidence that the identified gaps, which previously exposed the enterprise to cyber attackers, are successfully fixed. Pen tests can also be used to test any new measures, policies, or procedures implemented in an organization. Additionally, this is the reason why many regulatory standards recommend (or mandate) an assessment following the addition or modification of a company’s cybersecurity program. Also, it allows organizations to prioritize their risks.

Primarily focusing on security, the defined standards are designed to hold organizations accountable regarding the management of their cybersecurity risks. They require that companies should perform due diligence on security controls of their IT systems. These regulatory frameworks include specific compliance guidelines related to penetration testing.

The need for pentest as per different security standards.

Penetration testing is required and being mentioned as a control in various information security standards.

ISO27001
PCI DSS
HIPAA HITRUST
GDPR
SOC 2

Penetration Testing in ISO27001

It is mentioned as in annexure control “A.12.6.1 – Information about technical vulnerabilities of information systems being used shall be obtained in a timely fashion, the organization’s exposure to such vulnerabilities evaluated and appropriate measures taken to address the associated risk.”

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There are lots of other assessment techniques that can be used to fulfill the ISO 27001 requirements, but penetration testing leaves no leeway and avail appropriate measures to match the known risks, confirming that the requirement is met with no False positives. Other methodology, like vulnerability assessment, partially pleases the A.12.6.1 requirement, as it just provides information about the technical vulnerabilities. It does not help with the necessary action to address the identified risks, making the compliance process merely efficient and straightforward.

Penetration Testing in PCI DSS compliance

According to PCI-DSS compliance, the below requirements suggest the importance and compulsion comply with Penetration Testing

As per controls 6.1, 6.2 & 6.6 of the PCI standard, It is mandatory to Identify the vulnerabilities for critical applications (Internal or External) with the use of reputed software, assign risk rating, protect software and system components from known vulnerabilities by installing critical patches within months’ time of its release, and be ready to address new threats and vulnerabilities for web-based application on regular basis. This gives assurance to all applications, software, and system components.

As per controls 11.3 of PCI DSS standards, the Organization is required to conduct Penetration Testing (Internal & External) through independent auditors once a year and after any significant change or upgrades to IT Infrastructure/application, All the vulnerabilities identified during the pentest procedure should be addressed and reviewed until it is resolved.

To maintain PCI DSS compliance, organizations must implement an effective penetration testing program that covers an annual penetration test for critical applications and infrastructure along with a vulnerability management program to assure that identified vulnerabilities are remediated properly and in time. Moreover, any system component involved in Transmitting, storing, and processing Payment or card data must be scanned to identify every possible way hackers could compromise systems—whether they are web applications, APIs, or internal networks where credit cards pass.

Penetration Testing in HIPAA

The HIPAA Security Rule requires healthcare organizations to document a regular vulnerability scan to assess healthcare devices, applications, and networks for common vulnerabilities and exploits or security weaknesses. Viewed as foundational to compliance, this assessment demands evaluation of risks and vulnerabilities and implementation of “reasonable and appropriate security measures to protect…the security or integrity of ePHI [electronic Protected Health Information].”. This may include quarterly or annual vulnerability tests, penetration tests, and annual checks on the technical security configuration of your systems.

HIPAA vulnerability scan provides information about flaws or weaknesses in the development of information systems and for incorrectly implemented and/or configured information systems and Penetration testing can reveal the real-world ways in which hackers might compromise personnel, physical premises, and networks and IT assets thus making these requirements as a necessary requirement in securing the patient data.

Penetration Testing in GDPR

“Article 32 – Implement a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.”

While the GDPR requirement in the context of penetration testing represents a very small component of the standard, it permits organizations to not only be compliant with GDPR standard but also help to safeguard the organization from sudden cybersecurity incidents and avoid huge penalties that can sum up to 20 million euros if a breach has happened.

Furthermore, as per the Information Commissioner’s Office, the regulatory body that enforces GDPR in the UK, even they are required to “Run regular vulnerability scans and penetration tests to scan their systems for known vulnerabilities—and confirm that they address all vulnerabilities identified” in order to comply with GDPR.

Penetration Testing in SOC2

“CC4.1 – Management uses a variety of different types of ongoing and separate evaluations, including penetration testing, independent certifications made against established specifications (for example, ISO certifications), and internal audit assessments.

CC7.1 – To meet its objectives, the entity uses detection and monitoring procedures to identify

(1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities to newly discovered vulnerabilities.”

The SOC 2 need for conducting penetration testing is not as mandatory as other standards request for, but it can be interpreted in various ways. However, the two compliance requirements that are directly mentioned for the use of penetration testing or similar techniques with regards to the identification of vulnerabilities in the company’s systems—explain why most auditors require penetration testing for SOC 2 compliance. They are widely used to achieve SOC 2 compliance for the simple reason that they allow organizations to meet these two requirements in the best way possible.

Conclusion

Penetration Testing is one of the most necessary and formidable parts of the compliance requirements of various compliance standards, as it is one of the most efficient methodologies of cybersecurity assessment, and it makes organizations identify the risk in their Infrastructure and Network. Apart from the compliance requirements, there are many good reasons to make sure pen-testing occurs on an ongoing basis to maintain a secure environment as it changes and evolves to meet business or compliance demands. Every enterprise must perform PenTest so that there is no amiss of critical gaps which can lead to Cyberattack and suffering from huge Financial, Legal, and Reputational losses.