Who needs a Penetration Test?

Penetration testing is fundamental to creating a holistic and vigorous cybersecurity framework for any organization. Business ventures often contemplate why they have to consider undertaking a penetration test. The answer is simple, apart from leveraging the numerous operational benefits that practicing regular penetration testing brings, it also forms a vital part of retaining regulatory compliance.

Countless regulations and cybersecurity standards globally vouch for penetration testing. They have even mandated undertaking penetration tests at regular intervals for liable business organizations. Are you also required to comply with the penetration testing requirement? We can help you navigate through the different aspects of this question. NaviSec experts bring forth some key regulations that call for timely penetration testing and shall enable you to stay compliant and avoid any regulatory penalties.

Notable regulations and authorities that call for regular penetration testing!


PCI DSS, also known as the Payment Card Industry Data Security Standards, governs any form of business venture that accepts or processes card payments. It encompasses merchants, financial institutions, processors, allied service providers, and other organizations indulged in collecting, storing, or transmitting sensitive cardholder details.

PCI DSS v.32 calls for external penetration testing in all liable entities to ensure the sustenance of the required security framework. PCI council offers detailed guidance on how organizations can conduct a penetration test. 

The objectives of PCI penetration testing include:

  • Determining the possibility of unauthorized access by an illegitimate user and the approach he utilizes to enter the fundamental security system, logs, and other files of a cardholder.
  • Confirming that the appropriate controls related to scope, methodology, vulnerability management, and segmentation as outlined by PCI DSS remain in effect.
  • As per the PCI DSS norms, a qualified internal resource with required organizational independence or a qualified third party should conduct a penetration test. PCI pentesting guide mentions using pentesters with relevant past experience and industry-recognized certifications.
  • It is also critical to note that a regular vulnerability assessment is not a PCI penetration test. PCI DSS treats vulnerability scanning as a totally distinct process with a separate set of requirements.
  • Pentesting professionals perform PCI pentests using the gray box or white box approaches.
  • The scope of a PCI penetration test should cover the entire cardholder data environment perimeter and associated critical systems. The penetration testing team should follow the rules of engagement that the PCI DSS Council has specified.
  • Compliant organizations must conduct PCI penetration testing at least once every six months.


The Gramm-Leach Bliley Act, 1999 (GLBA) is another critical regulation that oversees financial institutions and their allied entities handling confidential financial data of customers called personally identifiable information. GLBA asks for covered financial institutions and businesses to fulfill specific testing compliance, including periodic penetration testing.

  • The recently revamped Safeguards Rule of this regulation has a specific definition for penetration testing. It defines a penetration test as a testing methodology wherein assessors try to evade data security features of a given system internally or externally, as needed.
  • The rule also calls for liable financial institutions to either include continuous monitoring or undertake annual penetration testing and half-yearly vulnerability scans of their cybersecurity framework as part of their overall security testing.
  • GLBA penetration testing is not any simple gap analysis or automated system checks. It is a robust process that needs to be undertaken with expert assistance.

The Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act represents a US federal statute that offers data security and privacy regulations for shielding health data against ransomware and cyber exploits. The HIPAA privacy rule acts as one of its kind standards in the US to safeguard personal and protected health information. The answer can be a bit perplexing when considering whether HIPAA requires penetration testing.

  • There is no explicit regulation that states that HIPAA calls for penetration testing. However, there are many applicable information security requisites that liable organizations can best mitigate with HIPAA penetration testing. Many professional bodies, including NIST (National Institute of Standards and Technology), recommend performing penetration tests to manage HIPAA compliance.
  • HIPAA’s security rules have some primary objectives that healthcare organizations can cater to effectively with appropriate testing techniques like penetration testing and vulnerability scans.
  • The information access management section of the HIPAA needs the assessment of security measures regarding access controls, along with checking the effectiveness of authentication approaches to ward off unauthorized access.
  • HIPAA’s section on Evaluation states the use of specific technical and non-technical evaluation methodologies. The official guidance note mentions internal/external penetration testing as the suggested method for technical examination of the security controls, wherever possible.


SOC 2 represents a set of compliance standards brought forth by the American Institute of CPAs for various service entities. It delineates the way different service providers must manage their client data. SOC 2 aims to uphold the five security principles of security, integrity, availability, confidentiality, and privacy.

  • It is not compulsory to carry out penetration tests as per SOC 2 requirements. However, penetration tests prove essential to make sure that there are no instances of unauthorized access to a client’s sensitive information and that the necessary controls remain in place. It helps seamlessly implement the SOC 2 audit that all business ventures holding SOC 2 certification must conduct.
  • Certain aspects of the SOC 2 law outright mention performing penetration testing. The SOC 2 Type II Points of Focus have statements suggesting the implementation of SOC 2 penetration tests as evaluation methods.

General Data Protection Regulation (GDPR)

GDPR is one of the keystone regulatory frameworks to protect the personal data of citizens residing in the European Union. It not only applies to companies functioning in Europe but also brings into its nexus any organization that handles data of EU citizens.

  • A brief view of the GDPR requirements may lead to the interpretation that it does not mandate penetration testing. However, a deeper analysis will point out that penetration testing can prove integral to ensuring abidance with GDPR. The regulation states the performance of a process for regular testing, evaluating, and assessing organizational security measures.
  • GDPR has some very stringent penalties for data breaches that can go up to €20 million. Penetration testing is an apt tool to timely discover vulnerabilities and reports data breaches to prevent hefty penalties.

The California Consumer Privacy Act (CCPA)

CCPA is a state-wide data privacy legislation that oversees the management of the personal data of California residents by organizations worldwide.

  • The law calls for reasonable security practices to protect personal information against unauthorized access and exfiltration. It does not patently mention the use of penetration testing but does recommend it in a broader sense.
  • Penetration testing can prove fundamental as a cybersecurity best practice and a proactive measure to follow CCPA requirements. It can help in keeping at bay penalties and damages that can be around $750 per consumer.


The Financial Industry Regulatory Authority acts as an independent self-regulatory organization that frames regulations for registered brokerage firms and broker-dealer concerns in the US.

  • FINRA does not straightforwardly mention the implementation of regular penetration testing in its rules. However, it has suggested the use of penetration testing in its report on Selected Cybersecurity Best practices
  • The authority also enumerates certain practices beneficial while conducting penetration tests. It desires all relevant business entities to undertake a strong penetration testing program with a risk-based approach and duly vetting third-party security providers.

The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA)

This Canadian law administers how private sector entities assimilate, utilize, and disclose personal information in the course of their business operations.

  • PIPEDA has proposed the usage of penetration testing as a best practice to avoid privacy breaches. The regulation asks private companies to hold vulnerability scans and penetration tests to identify privacy threats.  

Are you an organization that falls under the purview of any such regulations or authorities as mentioned above? In that case, you have to oversee the suitable implementation of penetration tests on your premises. Any laxity in this measure can not just lead to non-compliance issues but also cause detrimental effects on your data security posture.

NaviSec can help you steer your way in adhering to timely compliance with its cybersecurity adroitness.

NaviSec can be your iconic partner in your journey to sustaining holistic regulatory compliance in the cybersecurity domain!
There are tons of regulations and certified authorities that point their fingers at the practice of performing regular penetration testing. We help you identify the compliances you need to mitigate and conduct robust penetration testing programs tailored to your business. Contact our team to up your cybersecurity game!

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