The process for scoping internal PCI pen tests
- TAGS:PCI, penetration testing
- IT TOPICS:Government & Regulation, Security
I wanted to lay out the typical process that I go through when meeting with a client who needs a penetration test for PCI compliance. I think this will be helpful for those of you involved in these types of engagements.
- You have a meeting with the client who needs a pen test for PCI
- You quickly realize that your client does not know that a clarification was issued that states that pen testing is defined as INTERNAL and EXTERNAL, not just external
- When you mention this clarification, they look at you like you've lost your mind
- Then they look incredulous
- Then they question your sanity
- Then they think you are trying to rip them off
- Then you produce the clarification document (this is a 11.3 supplement document – have this with you AT ALL TIMES)
- Then they look incredulous again
- Then they start thinking about how this is going to cost them more money
- Then their ears start smoking
- Then their eyes start bleeding
- Then they rant and rave at PCI and how it is not fair
- Then they come full circle and start breathing normally again because they think it can’t be too bad because they have credit card data on only two servers
- Then you ask them if they have segmented off their internal credit card environment
- They say no (almost always) and you resist the urge to shake your head and laugh
- Then you state that they will need to perform an assessment of their entire environment
- Then symptoms from numbers 10 and 11 return
- Then you finally get the information you need from them and scope the engagement
- They get the SOW and start crying
- Then they become incredulous… AGAIN
- Then they say there is no way they can pay for this
- You tell them they would not have to pay this much if they segment off their CC environment
- They talk to their QSA, who gives them a different scope
- Confusion and cursing ensue
- You scope again and you put down in writing that you don't accept responsibility if they don't pass an audit because the scope of the penetration test was not correct
- The client gets nervous and goes back to the QSA
- The client is informed that their auditor has left the company and they are assigned a new auditor
- Their new auditor redefines the scope
100. Skipping to the end… the client commits suicide…
And the process begins again with the poor bastard who gets promoted.

