Penetration Testing for Compliance: A Complete Guide

Application security demands a thorough and multifaceted approach. Ensuring the safety of your application means testing it from every possible angle—both from within the internal environment and from external threats. 

Penetration testing is one of the best methods for achieving this level of security assurance from external threats. Penetration testing (pen testing) is a simulated attack on an application, system, or network,  to identify and exploit security vulnerabilities. This type of testing is performed by an experience third party and helps organizations proactively discover and fix security weaknesses, prevent real-world attacks, and ensure data protection. 

Pen testing also helps organizations maintain compliance with industry standards and regulations. Some regulatory bodies either mandate or recommend conducting penetration tests to ensure the security and integrity of an organization's information systems.

These standards and regulations often dictate the frequency, scope, methodology, and reporting requirements for penetration tests to protect sensitive data and maintain overall cybersecurity. The process of using pen testing to ensure compliance is called penetration testing for compliance or compliance-focused pen testing.

We’ll provide a deep dive into pen testing for compliance, covering why it’s important, how it works, what challenges to expect, and how to implement this process successfully. 

The Importance of Compliance in Application Security 

Adhering to regulatory requirements ensures that your organization meets the legal standards set by various local and international governing bodies to ensure the security, privacy, and efficiency of various practices within specific industries. Non-compliance can result in fines, legal actions, and damage to your organization's reputation.

Compliance also helps protect sensitive data. Regulatory standards often include stringent data protection measures that mitigate the risk of data breaches. By following these standards, organizations can safeguard personal, financial, and confidential information, reducing the potential for data loss and cyberattacks.

Perhaps most importantly, compliance fosters trust and confidence. Clients and partners are likelier to work with businesses committed to security and regulatory adherence. This trust often translates to a competitive advantage, enhancing your organization's market position.

Regular compliance checks and audits also drive continuous improvement in security practices. They encourage organizations to stay updated with the latest security trends and threats.

Regulatory Frameworks and Penetration Testing

Several regulatory frameworks that either mandate or strongly recommend penetration testing to ensure the security of information systems include:

• Payment Card Industry Data Security Standard (PCI-DSS): Regular network penetration testing is mandatory for organizations handling payment card information to ensure cardholder data security and prevent data breaches.

• Health Insurance Portability and Accountability Act (HIPAA): While not explicitly required, penetration testing is highly recommended to protect the integrity of protected health information (PHI).

• General Data Protection Regulation (GDPR): Penetration testing is recommended to ensure data protection by design and by default to protect the personal data of EU citizens.

• International Organization for Standardization (ISO 27001): Regular penetration testing is advised to ensure information asset security and adequate security controls.

• National Institute of Standards and Technology (NIST): NIST offers guidelines for conducting penetration testing to improve the security posture of federal agencies and other organizations adhering to NIST guidelines.

• Sarbanes-Oxley Act (SOX): Penetration testing is not explicitly mandated, but it is often conducted by companies that must comply with SOX internal control requirements to ensure the accuracy of financial reporting.
  
  

A few other frameworks that compliance-focused pen testing is recommended for include the Federal Information Security Management Act (FISMA), the California Consumer Privacy Act (CCPA), and the Gramm-Leach-Bliley Act (GLBA).

Key Components of Penetration Testing for Compliance

Before beginning the penetration testing compliance procedure, clearly defining the pen test's scope is essential. This step is needed to ensure that all critical systems and applications are tested. 

Defining the scope of penetration testing involves specifying the boundaries, including the specific network segments, systems, applications, and data flows to be tested. Boundaries ensure a focused and comprehensive assessment. 

Exclusions are equally important—identifying systems, data, or operational areas off-limits due to stability concerns, legal constraints, or third-party management. This clear delineation helps set expectations and ensures testing meets organizational and compliance requirements.

The next step is to select a methodology. The methodology used for penetration testing should be robust, standardized, and compliant with industry best practices. It guides the testing process, ensuring consistency and thoroughness.  Choosing the proper methodology ensures that the testing process is systematic, repeatable, and covers all necessary aspects of security assessment.

Some of the most commonly used methodologies include:

• OWASP (Open Web Application Security Project): Focuses on web application security and is widely used for identifying vulnerabilities in web applications.

• PTES (Penetration Testing Execution Standard): Provides a comprehensive framework for conducting penetration tests.

• NIST SP 800-115: Offers information security testing and assessment guidelines.
  
  

Comprehensive reporting and documentation are crucial for demonstrating compliance, communicating findings, and guiding remediation efforts. Some of the most common components of this phase include:

• An executive summary that offers a detailed overview of the findings and their impact on the organization.

• The aforementioned detailed findings that list all identified vulnerabilities, their severity, and potential impact.
  
  
• Evidence to back up your findings, providing concrete proof of identified vulnerabilities (screenshots, logs, code snippets, etc.), that demonstrate how the vulnerabilities were discovered and can be exploited. 

The next step involves planning how to attack the vulnerabilities that were uncovered. Pen testing compliance procedures should result in concrete recommendations for actionable remediation and risk mitigation steps. A well-structured remediation plan ensures that vulnerabilities are effectively addressed, reducing the risk of exploitation and enhancing overall security.

Classify vulnerabilities according to severity and potential impact. Develop a step-by-step plan to address each vulnerability, including timelines and responsible parties.

Finally, your security team should agree to a regular pen testing schedule. Cyber threats evolve constantly, making continuous assessment crucial. The frequency of testing should align with regulatory requirements and industry best practices. Standard intervals include annually, semi-annually, or quarterly, depending on the sensitivity of the systems and data involved.

Best Practices for Compliance-Oriented Penetration Testing

Traditional point-in-time penetration tests provide a snapshot of your security posture but can miss emerging threats. Adopting a continuous testing approach helps identify vulnerabilities as they arise. Schedule regular comprehensive penetration tests (e.g., quarterly or bi-annually) to evaluate all systems and applications thoroughly.

Use the insights gained from penetration testing to enhance your broader risk management efforts. Incorporate vulnerability data into your risk assessment processes to understand their potential impact. Categorize and prioritize vulnerabilities based on their severity, potential impact, and the likelihood of exploitation. Focus on high-risk vulnerabilities that could cause significant damage if left unaddressed.

Communicate the penetration testing results and the associated risks to key stakeholders, including executive leadership, IT teams, and business units. Transparency helps in securing necessary resources and support for remediation efforts. Regularly update your security policies according to the findings from penetration tests. This ensures that your security practices evolve with emerging threats and regulatory changes.

Regularly train your staff on the latest security threats and best practices. Awareness programs can aid employees in recognizing and responding to potential security incidents, complementing technical defenses.

If possible, extend your penetration testing efforts to include third-party vendors and partners with access to your systems and data. Ensuring their security practices align with your standards reduces the risk of supply chain attacks.

Find Trusted and Experienced Pen Testing Partners 

To maximize the effectiveness of your compliance-focused penetration testing, engage qualified and certified testers. Ensure your penetration testing team comprises professionals with relevant certifications such as Offensive Security Certified Professional (OSCP), Certified Ethical Hacker (CEH), or Certified Information Systems Security Professional (CISSP). 

Choose testers with extensive experience in your industry and familiarity with its specific regulatory requirements. 

Penetration testing via Codacy is conducted by our partners TargetDefense/Bulletproof, a trusted name in pen testing since 2016. With a Codacy Pro subscription, you get the peace of mind of an additional scan or report required for regulation, affordable pricing with an exclusive discount, and the ability to see unified results back in Codacy.

If you are interested, schedule your pen test through Codacy today.