Understanding PCI DSS Penetration Testing Process and Methodology

To understand the PCI DSS penetration testing process and methodology, it's essential to grasp the scope of the assessment. The penetration testing process typically begins with a reconnaissance phase, where the tester gathers information about the target environment.

This phase involves identifying potential vulnerabilities and weaknesses in the system. The tester will use various tools and techniques to gather information, such as network scanning and social engineering.

The next phase is the vulnerability identification and exploitation phase. Here, the tester will attempt to exploit identified vulnerabilities to gain unauthorized access to the system. This phase can be divided into two main categories: low-level and high-level attacks.

Low-level attacks involve exploiting simple vulnerabilities, such as SQL injection or cross-site scripting. High-level attacks, on the other hand, involve more complex attacks, such as buffer overflow or remote code execution.

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PCI DSS compliance is a must for any organization that handles credit card information.

The Payment Card Industry Data Security Standard (PCI DSS) has 12 main requirements that must be met, including installing and maintaining a firewall configuration to protect cardholder data.

Regular vulnerability scanning is necessary to identify potential security threats.

The PCI DSS compliance process involves multiple steps, including gathering information about your organization and its cardholder data environment.

You'll need to provide a list of all system components that store, process, or transmit cardholder data.

This includes servers, databases, and other systems that interact with cardholder data.

The PCI DSS compliance deadline is typically 90 days after the compliance scan is completed.

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Penetration testing is a crucial part of PCI DSS compliance, and it's essential to understand what it entails.

Penetration testing is a manual process of exploitation that involves identifying vulnerabilities and attempting to circumvent or defeat security controls. This process is separate from vulnerability scanning or assessments, which are also required for PCI DSS compliance.

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A vulnerability assessment is highly automated and may combine multiple tools with manual verification, whereas penetration testing is a more hands-on approach that includes or may include automated tools to identify vulnerabilities.

To give you a better idea of the scope of penetration testing, consider the following:

The time required to complete a PCI penetration test can vary greatly, depending on the scope and complexity of the environment. For a low complexity environment, it could be completed in as little as a week, while a highly complex organization may take over a month to complete the test.

There are several methodologies used for penetration testing, and the choice of methodology depends on the company offering the service and the organization being tested. Industry-accepted methodologies include the Open Source Security Testing Methodology Manual, The National Institute of Standards and Technology Special Publication 800-115, OWASP Testing Guide, Penetration Testing Execution Standard, and Penetration Testing Framework.

Penetration testing involves a manual process of exploitation, which may include automated tools to identify vulnerabilities. This is in contrast to vulnerability scanning or assessment, which is a highly automated process that identifies, ranks, and reports on vulnerabilities.

To achieve PCI-DSS compliance, penetration testing must be conducted according to a specific methodology. The PCI-DSS 3-2-1 requirement 11.3 stipulates that testing must be based on NIST SP800-115.

Here are some key testing requirements:

A vulnerability scan and a penetration test are often confused with each other, but they serve different purposes.

A vulnerability scan is focused on finding, prioritizing, and reporting vulnerabilities that exist in a system using an automated tool.

The goal of a vulnerability scan is to find and report on existing vulnerabilities, whereas a penetration test aims to discover vulnerabilities and exploit them to discover deeper threats.

A vulnerability scan is typically performed by an ASV (Authorized Scanning Vendor) for external scans and qualified personnel or a third-party for internal scans.

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In contrast, a penetration test is performed by qualified internal personnel or a third-party, who must have a penetration testing methodology and experience.

Here's a breakdown of the major differences between a vulnerability scan and penetration test:

Understanding the differences between a vulnerability scan and a penetration test can help you choose the right testing approach for your organization's needs.

There are several methodologies that can be used for penetration testing, but the specific approach depends on the company offering the service and the organization being tested.

The Open Source Security Testing Methodology Manual ("OSSTMM") is one of the industry-accepted methodologies that pen testers may use.

The National Institute of Standards and Technology ("NIST") Special Publication 800-115 is also widely accepted and required by PCI-DSS 3-2-1, requirement 11.3.

OWASP Testing Guide and Penetration Testing Execution Standard (PTES) are other methodologies that pen testers may use.

Penetration Testing Framework is another methodology that can be used.

The PCI-DSS 3-2-1, requirement 11.3 requires that an organization implement a methodology or capability of testing based on NIST SP800-115.

The scope of testing must include the full cardholder data environment (CDE), critical systems, and supporting systems for that environment.

The testing must also include segmentation validation testing, network-layer testing, and application layer testing.

The PCI-DSS defines that app pen testing must include tests against the OWASP Top 10 for any application or service that is residing within the CDE.

Here are some industry-accepted methodologies that pen testers may use:

PCI-DSS penetration testing is based on NIST SP800-115, and testing must include the full cardholder data environment (CDE), critical systems, and supporting systems.

The PCI-DSS 3-2-1 requirement 11.3 stipulates that internal and external network testing must be conducted, including segmentation validation testing.

This means that any environment interacting or storing CHD must have internal and external testing conducted against it to validate that the CHD is not exposed.

Network-layer testing and application layer testing are also required as part of the scope.

PCI-DSS further defines that app pen testing must include tests against the OWASP Top 10 for any application or service within the CDE.

The contracted consultancy must be informed that the test will be used for PCI-DSS, and the methodology may include network segmentation testing and in-depth documentation.

This is not a typical approach for an internal penetration test, and it's essential to ask for it specifically.

The scope of PCI pen testing includes the full CDE, critical systems, and supporting systems, and it must be conducted by a qualified consultancy.

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A PCI penetration test can take anywhere from a week to over a month to complete, depending on the scope and complexity of the environment.

The time required to complete the test is directly related to the number of systems and segments in scope. As more systems and segments are added, the overall time to complete the test increases.

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For a low complexity environment, a penetration test can be completed in as little as a week. However, this timeframe can be significantly longer for highly complex organizations.

The complexity of the organization is a major factor in determining test duration. Internal penetration testing with segmentation validation can add significant time to the test.

The number of applications and APIs in scope also impacts the effort required to complete the test. Testing against these systems requires additional time and resources.

In addition to the number of systems and segments, the number of applications and APIs in scope will increase the overall effort to complete the test.

PCI DSS penetration testing can be a complex and costly process, but it's essential for organizations handling, processing, or storing payment card information. The frequency of penetration testing is defined by requirements 11.3.1 and 11.3.2 of the PCI-DSS document.

External penetration testing must be conducted at least annually and after any significant changes in infrastructure or applications. Internal penetration testing, on the other hand, must take place annually, with segmentation testing occurring every 6 months.

The cost of PCI penetration testing is also a significant factor to consider. The total number of live systems in scope will affect the cost, with more in-scope systems or IP addresses increasing the price. This is because every web application that is accessible, whether internal or external, must have some level of testing completed against it as part of the PCI penetration test.

The number of VLANs that need to be tested is also a major factor in the overall effort and cost of the PCI penetration test. PCI requires that all VLAN segmentation be tested to provide evidence of the inability to access or move cardholder data from a secured segmentation to another lower-tier segmentation.

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Reducing costs is a top priority for many organizations, and PCI penetration testing is no exception. The cost of a PCI penetration test can range from $10,000 to over $100,000 per test, as mentioned in Example 4.

One of the easiest ways to reduce the overall testing cost is to only test the CDE assets, as stated in Example 5. This approach is not only valid but also expected by auditors, as it reduces the risk associated with having non-PCI systems in scope.

Selecting a vendor with a lower cost can also help reduce the overall cost of the test. However, be aware that this can introduce risk, as a low-budget vendor may not provide a comprehensive test, and the organization will still be at fault if a breach occurs.

The vendor's depth and quality can have a significant impact on the cost of the test, with some vendors doubling the total cost of PCI penetration testing. This is a critical factor to consider when selecting a vendor, as mentioned in Example 7.

Reducing the scope of the test by only testing the CDE assets can also help lower the testing cost. This approach may require a defined CDE environment, as mentioned in Example 2.

The number of VLANs that need to be tested can also impact the overall effort and cost of the test. PCI requires that all VLAN segmentation be tested, which can add to the cost, as mentioned in Example 6.

Ultimately, reducing costs requires a careful balance between compliance and security. By selecting a vendor that provides a comprehensive test and only testing the CDE assets, organizations can reduce the overall cost of the test while still meeting the requirements of PCI penetration testing.

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Penetration testing frequency is a crucial aspect of PCI DSS compliance. External penetration testing must be conducted at least annually and after any significant changes in infrastructure or applications.

Organizations must also perform internal penetration testing annually, with segmentation testing occurring every 6 months. This frequency applies to all PCI compliance levels, from 4 to level 1.

The more VLAN segmentations that are in scope for testing, the higher the cost. This is because PCI requires that all VLAN segmentation be tested to provide evidence of the inability to access or move cardholder data from a secured segmentation to another lower-tier segmentation.

Here's a breakdown of the required testing frequencies:

Organizations must also remediate any findings that are above a medium risk. This requires additional testing to validate that the findings are remediated properly.

Non-compliance with PCI penetration testing requirements can have severe consequences.

A risk rating of medium or above is a common reason for non-compliance, and it requires remediation or documentation of a mitigating control.

Remediation is a must, as most mitigation is temporary and will need to be addressed eventually.

Not remedying findings on a penetration testing report can lead to postponed certification, which can have severe impacts on an organization.

A postponed certification can leave an organization unable to process or handle credit cards until certification is reissued.

Conducting required testing last minute is not a viable solution, as it can still lead to certification revocation.

Revoked certification means an organization cannot process or handle credit cards until certification is attained.

The worst-case scenario is being levied with a fine, which can range from $5,000 to $100,000 per month for the violation.

Fines can continue until certification is attained, and may also lead to the bank or partner terminating the relationship with the organization.

Regular security system testing is a must. Regular assessment of systems and processes is a key control mandated by PCI DSS to protect cardholder data.

To manage cyber risk and information security governance issues, you can use Kroll's defensible cyber security strategy framework. This will help you stay on top of security and governance.

Organisations must perform internal and external penetration testing at least annually, or after any significant changes to infrastructure, as outlined in Requirement 11 of the PCI DSS standard.

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Regular security systems and processes are crucial to protect cardholder data. Regular assessment of systems and processes is among the key controls mandated by PCI DSS to protect cardholder data.

A penetration test is a type of cyber security assessment designed to identify, exploit and help address vulnerabilities. This includes assessment of network infrastructure and applications from both outside and inside an organisation’s network environment.

Organisations must regularly test security systems and processes in line with PCI DSS requirements. Requirement 11 of the standard outlines the need for organisations to perform internal and external penetration testing at least annually, or after any significant changes to infrastructure.

Cyber and Data Resilience is not just about reacting to incidents, but also about being proactive in preventing them. Incident response, digital forensics, breach notification, security strategy, managed security services, discovery solutions, and security transformation are all part of a comprehensive approach to security and governance.

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Cyber Governance is a critical component of overall security and governance. It involves managing cyber risk and information security governance issues.

A defensible cyber security strategy framework can help organizations navigate these complex issues. Kroll's framework is a valuable resource for this purpose.

Effective cyber governance requires a proactive approach to identifying and mitigating potential threats. This includes implementing robust security measures to protect sensitive information.

By prioritizing cyber governance, organizations can reduce the risk of cyber attacks and data breaches. This can help maintain trust with customers, partners, and stakeholders.

A well-designed cyber governance framework can also provide a clear understanding of an organization's security posture. This can inform strategic decisions and drive business growth.

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PCI DSS 4.0 was released on March 31, 2022, and the transition period will end exactly two years from that date on March 31, 2024.

Organizations have a generous transition period to review their reporting mechanisms and processes and formulate a plan to align their security practices with the new requirements.

The transition period is two years, allowing organizations to adjust to the new standard.

After March 31, 2024, PCI DSS 3.2.1 will be retired, and version 4.0 will become the new standard for organizations to follow.

Organizations can continue certifying their PCI DSS compliance by adhering to the requirements in version 3.2.1 until it is retired in 2024.

The rules for PCI DSS have changed relatively infrequently, with the last update being in March 2022.

Before that, PCI updated the requirements every 3 to 4 years.

The core requirements for penetration testing have not changed much, and it's expected that additional testing requirements may come out to account for new technologies.

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When selecting a PCI DSS penetration testing provider, consider their experience with similar clients. Look for a provider with a proven track record of successful penetration tests.

A reputable provider will have a team of skilled professionals, including penetration testers, security analysts, and project managers. This ensures that your test is conducted efficiently and effectively.

Ensure the provider you choose is certified by a recognized security organization, such as the PCI Security Standards Council. This certification demonstrates their expertise in PCI DSS compliance.

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When choosing a provider, you'll likely come across two main options: standard and enterprise editions. The main difference between the two lies in the level of guidance and frequency of testing required.

Standard editions typically have less specific requirements, whereas enterprise editions have more detailed guidance on the scope and frequency of testing. This is similar to the difference between a standard pen test and a PCI pen test.

A standard pen test may not require testing against the application-layer or critical systems, whereas an enterprise edition would typically include this as part of the testing scope. This is crucial for organizations handling sensitive cardholder data.

The enterprise edition also requires testing against connected systems, which is a critical aspect of the testing process. This level of detail is essential for organizations that need to ensure the highest level of security.

Redscan is a CREST-accredited provider of penetration testing services. This accreditation is a testament to their expertise and commitment to delivering high-quality services.

Redscan is an award-winning provider of penetration testing services. Their recognition in the industry speaks for itself.

Redscan's ethical hacking engagements help organisations achieve PCI DSS pen test standards. This is crucial for protecting card payment details from criminal attackers.

Redscan offers network penetration testing and web application testing services. These services are designed to identify weaknesses that could compromise sensitive information.

If you're looking for a reliable provider to protect your business, consider getting a quote from a company with a proven track record. They have been accredited as one of the highest in the UK for their penetration testing services.

Their team has a deep understanding of how hackers operate, which is crucial for effective risk remediation. This expertise allows them to provide in-depth threat analysis and advice you can trust.

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Before a PCI DSS penetration test can begin, the pen tester and organization need to identify the test's scope based on PCI DSS requirements. This involves considering critical systems, connected-to systems or networks, externally facing or publicly facing systems, and isolated environments for segmentation testing.

The scope of the test will determine what systems and networks are included and what areas will be focused on during the penetration test. The pen tester will then gain authorization for the test, stating the specific dates and times testing will occur, potentially including the IP addresses the penetration test will originate from.

Any credentials and authentication used during the test will be tested prior to the penetration test to ensure access is granted properly, so it's essential to get this right from the start.

You'll need to hire a qualified individual to perform a compliance assessment. This person must be organizationally independent, meaning they can't be responsible for the management, support, or maintenance of the target systems or environment.

A third-party firm is recommended, but PCI DSS does allow an internal resource to perform the assessment. This individual must have past experience as a penetration tester or hold a relevant certification, such as an Offensive Security Certified Professional (OSCP) or Certified Ethical Hacker (CEH).

To ensure they're qualified, look for someone with experience or certifications like a Global Information Assurance Certification (GIAC).

Before a penetration test begins, it's essential to define the scope of the test. The scope should include any critical systems, connected-to systems or networks, externally facing or publicly facing systems, and isolated environments for segmentation testing.

The PCI DSS specifies that the scope of a PCI pen test should include any critical systems, connected-to systems or networks, externally facing or publicly facing systems, and isolated environments for segmentation testing.

The pen tester will then gain authorization for the test, stating the specific dates and times testing will occur, potentially including the IP addresses the penetration test will originate from.

Any credentials and authentication will then be tested prior to the penetration test to ensure access is granted properly.

Choosing the right vendor for your PCI penetration test can make a big difference in the total cost. Some firms specialize in providing PCI penetration testing for a lower cost, but this often means a more focused and minimalistic approach.

The cost of a vendor can vary significantly, with some vendors doubling the total cost of PCI penetration testing. This is not just about selecting a check-box vendor versus a highly skilled vendor.

Selecting a vendor with a more robust and in-depth approach can provide a more comprehensive report, but it may come at a higher cost. If you're looking for a cost-effective option, a check-box vendor might be a valid approach for PCI.

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A PCI DSS penetration test can be a costly endeavor, but there are ways to optimize costs without compromising security. The average cost of a PCI penetration test is between $10,000 to over $100,000 per test.

The total number of live systems in scope will affect the cost, with more in-scope systems or IP addresses increasing the price. This is because PCI penetration testing requires testing against exposed applications without credentials.

The total number of VLANs that need to be tested also impacts the overall effort and cost of the test. PCI requires that all VLAN segmentation be tested to provide evidence of the inability to access or move cardholder data.

Selecting a vendor with a high level of expertise can double the total cost of PCI penetration testing. However, this may be a worthwhile investment to ensure the quality of the test.

One way to reduce testing costs is to only test the Cardholder Data Environment (CDE) assets. This is a valid approach and is not looked at negatively by auditors.

Offshore and VLAN testing can be a complex and costly endeavor. PCI requires that all VLAN segmentation be tested to provide evidence of the inability to access or move cardholder data from a secured segmentation to another lower-tier segmentation.

The more VLAN segmentations that are in scope for testing, the higher the cost. This testing is required to take place every 6 months, which is typically paired with the internal penetration test.

Organizations with multiple VLANs will need to allocate more resources and time for testing. This can be a significant challenge, especially for those with complex network infrastructures.

The cost of VLAN testing can add up quickly, especially when paired with internal penetration testing. It's essential to factor this into your budget and planning for PCI DSS compliance.

The cost of PCI DSS penetration testing can be a significant factor to consider. The total number of live systems in scope will affect the cost, with more in-scope systems or IP addresses increasing the price.

Having a one-to-many relationship with applications, where more applications live than hosts, can also increase the cost. Every web application that is accessible, whether internal or external, must have some level of testing completed against it.

The cost of a cheap PCI penetration test may seem appealing, but it's essential to remember that just checking the box does not mean due diligence has been completed. This can lead to additional fines and penalties if a breach were to occur.

The cost of non-compliance can be substantial, with fines ranging from $5,000 to $100,000 per month until the organization is in compliance again. Additionally, processors or banks may impose fines of between $50 and $90 per credit card.

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