The best defense is a potent offense. That’s the thinking behind the “ethical hacking” cybersecurity practice known as penetration testing (pen-testing). To understand which vulnerabilities a cybercriminal could exploit and how, it’s best to test them out yourself — or with the help of an expert service provider. Pen-testing is ideal for ensuring all regulatory requirements are in place, such as those for SOC 2 compliance.
Read on to learn about SOC 2 penetration testing requirements and best practices.
What Are SOC 2 Penetration Testing Requirements?
To protect companies that store sensitive financial data, the American Institute of Certified Public Accountants (AICPA) developed Service and Organization Controls (SOC) based upon its Trust Services Criteria (TSC). For many companies, penetration testing can facilitate the adoption of these criteria and successful SOC 2 reporting. But is it required?
In this blog, we will cover the two ways to look at (and answer) the question of whether your company needs to implement penetration testing for SOC 2 compliance and cybersecurity:
- The short answer that there are technically no pen-testing requirements for SOC 2
- The long answer; that you should still implement pen-testing for SOC 2 (and why)
Let’s look at both to get a better understanding of SOC 2 penetration testing requirements.
Short Answer: There Are No SOC 2 Pen-Test Requirements
Penetration testing is one of the most potent and flexible kinds of analysis you can use to optimize your cyberdefenses. Nevertheless, it is not strictly required for SOC 2 compliance. In fact, in the most recent update to the TSC (2020), “penetration testing” appears just once. It’s not a control, but one of many “different types of ongoing and special evaluations” organizations might consider as an additional focus.
However, the fact that pen-testing is not required is not a reason to ignore its potential.
SOC 2 compliance is relatively lax with respect to challenging requirements. Unlike other regulatory compliance frameworks, it’s not a set of controls to implement. Instead, it’s a set of principles companies need to consider when crafting their flexible solutions.
What Controls Does SOC 2 Require, and For Which Companies?
As noted above, SOC is based on AICPA’s TSC. This framework is relatively straightforward. It’s made up of five primary “trust categories,” previously referred to as principles:
- Security – Protecting against unauthorized access, disclosure of information, and use
- Availability – Providing access to data users who have a right or privilege to access
- Processing integrity – Ensuring all processes function according to their design
- Confidentiality – Safeguarding unique, sensitive information per defined limits
- Privacy – Restricting collection, use, and retention of personal information
These break down further into nine common criteria (CC) series within the security category and four additional criteria series for the remaining categories. Each series also breaks down into multiple individual controls and sub controls for which there are explanatory “points of focus” provided for each — and that’s where penetration testing gets a mention.
Long Answer: You Still Need SOC 2 Penetration Testing
Despite pen-testing not being a requirement for SOC 2 compliance, it’s still a powerful tool that can help you meet other audit requirements and protect your stakeholders. As noted above, the AICPA’s TSC designates pen-testing as one option to consider for robust monitoring of vulnerabilities and risks (See CC4.1). Let’s take a look at two of these:
- The specific practice of penetration testing in internal, external, and hybrid forms
- The more general area of vulnerability management, including vulnerability scans
Both practices are de facto necessities of a robust cyberdefense architecture. They are just as essential as basic measures like firewalls and antivirus software. New and evolving threats of cybercrime require the most advanced criteria to meet or overcome them.
Optimizing Penetration Testing for SOC 2 Compliance
Penetration testing is one of the most complex methods for cyberdefense. It empowers unrivaled insights through real-time analytics of how a hacker would compromise your system. There are two primary forms of pen-testing to leverage for SOC 2 purposes:
- External – Also known as “black hat” or “black box” testing, the attacker begins without any knowledge of your systems. The goal is to understand their process from its beginning and the points of attack and entry. This type of testing works well for processing integrity and security.
- Internal – Also known as “white hat” or “white box” testing, the attacker begins with privileged knowledge about your company. The goal is to understand how the hacker moves once already inside, which is especially useful for monitoring availability during and after an attack.
Many companies opt for a hybrid of the two, sometimes referred to as “grey hat” or “grey box” testing, and this is one excellent way to optimize pen-testing to your SOC 2 needs. Depending on the structures in place for security, confidentiality, or privacy, a pen-test that begins externally and then continues internally could test all three categories at once.
Implementing Vulnerability Scans for SOC 2 Compliance
Another critical practice alluded to in the TSC not strictly required for SOC compliance is vulnerability scanning. This is closely related to pen-testing in that it offers deep insights into weaknesses. However, the significant difference is that it studies latent risks and threats rather than a live, simulated attack. In particular, a vulnerability scan should search for gaps and cracks in your cybersecurity architecture and user behaviors that could lead to an attack.
But that’s not all. A more robust risk and vulnerability management system should also regularly index your own company’s strategies against threats in your environment. This includes the physical locations of the business and threats common in the industry. Your team should also cross-reference broader catalogs, such as the common vulnerabilities and exposures list (CVE).
Other Best Practices for Achieving SOC 2 Compliance
Ultimately, whether you choose to implement pen-testing, vulnerability scanning, or any other optional practice for SOC 2 compliance depends on what kind of SOC 2 report you hope to generate. There are two primary kinds of reports, each of which has its relative benefits:
- A SOC 2 Type 1 Report offers a snapshot of your security practices at a given moment, affirming the design of your defenses. These reports are straightforward, with a short turnaround.
- A SOC Type 2 Report provides a longer-term look at how your security systems work over a given period. These reports can offer more assurance but at higher overall costs.
Many companies find that the best way to ensure SOC 2 compliance and get the most out of auditing and reporting is to work with a qualified service provider. RSI Security offers a suite of SOC 2 compliance advisory services that are scalable to your company’s needs and means.
Professional Analysis, Compliance, and Cyberdefense
Here at RSI Security, we know how integral compliance can be to a company, no matter the size or industry. But we also know that compliance is far from the end of cybersecurity; in fact, it’s a means to the end of fully protecting your personnel, clientele, and all stakeholders in your company.
Whether you need assistance with SOC 2 penetration testing or other cybersecurity services, we can provide the perfect solution. Contact RSI Security today for a consultation!