
PCI Penetration Testing. ASV, QSA, Internal, Third-party?
As a Qualified Security Assessor Company (QSAC) we often get asked by our clients if they are able to fulfil their ongoing PCI penetration testing requirements in-house. The short answer is it depends.
PCI DSS requirement 11.3 covers an organisations requirement for conducting an annual internal and external penetration test – including application tests. This differs from PCI DSS requirement 11.2 which addresses an organisations requirement for running quarterly internal and external network vulnerability scans. The latter must be run by an Approved Scanning Vendor (ASV). Both requirements must be performed at the mandated intervals or when significant changes take place in the network, infrastructure and applications (including upgrades).
There are key differences in the two requirements from a technical perspective as well. The vulnerability assessment identifies and reports noted issues, while the penetration test attempts to exploit the vulnerabilities to determine the extent of the issues and full business impact. The penetration testing is more manual and comprehensive than the vulnerability scans, and also must include application layer tests.
Applying the PCI SSC guidance, the annual penetration test does not strictly need to be conducted by a party external to your organisation. However, the testing does need to be performed by a suitably qualified party who are organisationally separate from the management of the systems being tested. The penetration test should be appropriate for the complexity and size of the organisation and include all in-scope locations. Both the penetration testing methodologies (black box/white box and types of tests) and results should be documented, and the scope must include all systems and networks in the cardholder data environment. These requirements may be difficult to demonstrate for smaller organisations with limited resources.
Other organisations prefer to outsource these requirements to an organisation which is totally focused on the delivery of these expert services and is able to deliver comprehensive independent results. At the end of the day conducting penetration testing should not just be about meeting your compliance obligations – it should lead to an improved security posture, and many believe this is best addressed by engaging a specialist firm.
About the Author
Sense of Security is Australia’s premier provider of a range of IT security and risk management solutions. Its services include IT security reviews, penetration testing, audit and PCI compliance. Sense of Security provides PCI compliance services through its team of QSA’s to many of the countries leading organisations.
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