Do You Need Penetration Testing for Compliance?

TL;DR:

• A lack of compliance is hindering sales, prompting security directors to focus on revenue goals.
• Penetration testing and vulnerability scanning are common security testing options for compliance.
• Prescriptive frameworks like PCI DSS outline specific testing requirements, while descriptive frameworks like SOC 2 are more vague.
• Penetration testing is recommended for most compliance frameworks due to its comprehensive nature.
• While vulnerability scanning is more affordable and faster, penetration testing is the safest bet for finding and remedying security vulnerabilities.

A lack of compliance is becoming a major barrier for sales, forcing security directors to be more in tune with their organization’s revenue and growth goals than ever before. To help ease this pressure, companies are seeking to fulfill compliance requirements faster.

In this article, we’re deep-diving into the two most common security testing options companies employ for their compliance initiatives: penetration testing and vulnerability scanning. We’ll also make a comparison of which one is most valuable to your project.

What is penetration testing?

When you’re beginning to work on earning your compliance, you’ll likely be informed by your auditor or compliance team that you should consider doing a penetration test. Some will say you need a penetration test. A penetration test is a comprehensive security assessment done by ethical hackers to measure the security defences that you currently have in your systems.

Typically, penetration testing involves testing all your security controls such as authentication, authorization, integrity, and confidentiality against industry standards. A good penetration test should also test your application’s business logic and ensure there are no bypasses that can lead to serious issues.

Penetration testing can be conducted on all types of systems, including web and mobile applications, IoT devices, infrastructures, and networks. There are various types of penetration tests such as black box, gray box, and white box testing that approach the test in different ways, but all leveraging a human hacker to do the testing.

What is vulnerability scanning?

When a company is debating on the type of security test that they want to conduct, the choice is usually made between penetration testing or vulnerability scanning. Using a vulnerability scanner means employing an automated tool that identifies high-level vulnerabilities in your application. This is good to know and to keep in mind as you learn about the nature of each compliance framework below.

The difference between a prescriptive and descriptive compliance framework

All compliance frameworks cover different areas and have different requirements. As such, the way that penetration testing is suggested or required also varies across each framework. To better understand this, it’s important to know that compliance frameworks can either be prescriptive or descriptive in how they approach the security testing requirement.

Prescriptive compliance frameworks

Prescriptive frameworks are extremely helpful because they outline exactly what you need to do. There is no beating around the bush. There are clear outlines for what constitutes a pass or a fail on your compliance. This makes it easy to know if you should get a penetration test, vulnerability scan, or neither.

This includes:

• PCI DSS
• FedRAMP
• NIST

Descriptive compliance frameworks

Descriptive frameworks, on the other hand, are much more vague. They often outline a recommendation to complete a form of security testing, but they don’t clarify the type of test that is needed or on which areas of your system(s) you need to have tested.

This includes:

• SOC 2
• HIPAA
• ISO 27001

What are the security requirements for each compliance framework?

Unsure if you need penetration testing or vulnerability scanning for your upcoming compliance audit? Customers who turn to Software Secured are often concerned about what that entails for each different compliance framework. Let’s dive into the most common compliance frameworks that our customers ask us about, including PCI DSS, HIPAA, SOC 2, and ISO 27001.

PCI DSS

PCI DSS stands for the Payment Card Industry Data Security Standard. It is a standard for any company (digital or non-digital) that manages or stores cardholder data from any payment card provider (including Mastercard, VISA, American Express, Discover, and JCB). This framework is very prescriptive and is very actionable for developing your security program. There are four compliance reference levels built into this framework:

• Level 1 is the highest level. It is for any merchant who processes over six million transactions annually OR any company that has suffered a data breach resulting in the capture of cardholder data. This level requires yearly penetration testing and quarterly vulnerability scans, among other security requirements.
• Level 2 is for any merchant who processes between one to six million transactions annually. At this level, merchants must complete quarterly security scans and a yearly self-assessment questionnaire.
• Level 3 is for any merchant who processes between 20,000 to one million transactions annually. Security testing requirements are the same as level 2.
• Level 4 is for any merchant who processes less than 20,000 transactions annually. There is no security testing requirement, but it is highly recommended to conduct the testing required in levels 2 and 3.

Even at levels that don’t require penetration testing, it is still recommended. No matter how many transactions your business processes each year, if you suffer a data breach that exposes customer cardholder data, you are automatically assigned to Level 1 which includes very strict and specific security requirements. This also may include a forensic investigation and other possible consequences that arise from your breach, such as legal fees, reputation risk, fines from card processing companies, and possible loss of card processing privileges (for companies that have experienced a breach multiple times).

For those companies who have adopted PCI DSS version 4, biannual penetration testing is required, and segmentation testing in some cases. 

HIPAA

The Health Insurance Portability and Accountability Act (HIPAA) is a major compliance framework for any company handling sensitive Protected Health Information (PHI) about their users. It is relevant to all covered entities (ie. doctors, nurses, insurance companies) as well as business associates (ie. lawyers, accountants, IT personnel in the healthcare industry) that may have access to PHI. HIPAA has descriptive privacy and security rules, which identify the following requirements relevant to security testing:

Under the Security Rule

• There is a “General Rule” to maintain reasonable and appropriate administrative, technical, and physical safeguards for protecting e-PHI (PHI data available digitally). Within this rule is a specific requirement to “Identify and protect against reasonably anticipated threats to the security or integrity of the information.” There is no specific method that is recommended for identifying anticipated threats, though the framework does ask businesses to opt for a solution that considers the company’s size, complexity, capabilities, infrastructure, costs, and impact of potential risks to e-PHI. Businesses need to consistently review their security practices to ensure it is up to date with the changing technology, risk, and business environments.
• Under the “Risk Analysis and Management Rule,” a requirement asks companies to build a risk analysis process that includes a minimum of four activities around the evaluation, implementation, documentation, and maintenance controls for risk management. Like the General Rule, there is also no specific method recommended under this rule.

Both a penetration test and vulnerability scan can help meet both rules.

Under the Privacy Rule

• Among many other requirements, there is an Administrative Requirement in the Privacy Rule to ensure Data Safeguards are in place. This includes “maintain[ing] reasonable and appropriate administrative, technical, and physical safeguards to prevent intentional or unintentional use or disclosure of protected health information…” A regular penetration test or vulnerability scan may be able to prove that proper technical safeguards are in place.

You can learn more about the HIPAA privacy rules here and security rules here.

SOC 2

SOC stands for System and Organization Controls and is relevant for service organizations. It was developed by the American Institute of CPAs (AICPA) to measure if an organization’s practices are sufficient for safeguarding any customer data that they may access, store, or transmit. This framework is descriptive.

• Reports on controls within a service organization that are relevant to the five “Trust Services Principles” including security, availability, processing integrity, confidentiality, and privacy of customer data.
• The framework looks at your internal controls, including your control environment, risk assessment, control activities, information and communications, and monitoring. Both penetration testing and vulnerability scanning can support risk assessment control, in addition to a multitude of other criteria.

SOC 2 is offered with two types of reports:

1. A Type 1 report is a “snapshot in time” look at your organization’s controls. A one-time penetration test or vulnerability scan will suffice for a Type 1 report.

2. A Type 2 report continuously monitors your organization’s information and privacy controls, for at least 3 months, typically once a year for 12-month cycles. If you are practicing more frequent testing for a Type 2 report, you may consider Penetration Testing as a Service (PTaaS) for quarterly penetration testing, or you can continue purchasing a one-time pentest or vulnerability scan each year.

ISO 27001

‍ISO 27001 was published by the International Organization for Standardization (ISO) to bring a benchmark for information security practices in enterprises. Companies that strive for ISO 27001 compliance need to renew this standard every three years at a minimum. It is a descriptive framework.

There are many control requirements which can be tested and proven through various security testing methods in Annex A. For example, there are control requirements regarding:

• Handling digital and physical assets
• Appropriate limiting of employee access to data
• Proper encryption of sensitive data
• Logging and monitoring of software and known vulnerabilities
• Technical vulnerability management
• Network security management
• Security of information as it shared within and outside of the organization‍

ISO 27001 is incredibly thorough in the number of aspects that it looks to seek protection on, but it doesn’t recommend one specific solution for testing the implementation of those protections. Vulnerability scanning can cover most security requirements but organizations should opt for a penetration test as it can cover all requirements.

The security testing requirements under each compliance framework

There's a lot of information out there and security compliance is complex. Building a security program is an iterative process, here are some quick points to make this decision a little easier.

Pros of getting a penetration test

• Comprehensive penetration tests usually produce a higher number of true positives and no false positives.
• Support with remediation following report delivery.
• Will meet the requirements for all compliance frameworks.
• Can upgrade anytime to Penetration Testing as a Service (PTaaS), which runs a penetration test quarterly.
• Support on completing self-assessment questionnaires and vendor security questionnaires.
• Assists in addressing other areas of your program to improve compliance (i.e. logging and monitoring, authentication and authorization, etc).
• Supports global sales expansion (ie. organizations in Europe can have more stringent requirements around data security and privacy).

Cons of getting a penetration test

• High-quality penetration tests can be expensive.
• As with any manual test, penetration tests take more time to schedule and execute‍.

Is a vulnerability scan sufficient for compliance?

In very rare cases, a vulnerability scan is enough. For example, if your client base isn't concerned with how their data or PII is secured. Or, if your company is focused solely on compliance and not investing in strong security measures for other business needs.

Pros of getting a vulnerability scan

• Much more affordable for smaller businesses.
• Little to no onboarding time after the tool is downloaded.
• Can be done in-house with a DAST tool.
• Faster results, usually within 24 hours.

Cons of getting a vulnerability scan

• May not be suitable for all types of compliance.
• Only finds high-level vulnerabilities so potentially leaves deeper, unidentified security gaps.
• Often produces false positives, which adds an administrative burden to your technical team.

Things that both will provide:

• A report outlining the vulnerabilities, often both in an online dashboard and a downloadable report file (ie. .docx, html, pdf, etc.).
• Both will work with almost any programming language or framework.

The ultimate answer

If you have the budget and time, getting a penetration test is your safest bet. Not only will you find more vulnerabilities, but you will also receive support for remediating these security gaps before your compliance audit. You will have much higher confidence in the software you are delivering and you will prove your commitment to security to your enterprise clients. Having a better score on your compliance certification will help you close more sales - so think of it as an investment for your future revenue.