Since June 2023, the robust GLBA penetration testing and vulnerability scanning requirements have been in place, marking a proactive step in the face of the increasing prevalence of data breaches. This proactive approach is a testament to the readiness and control that businesses in most sectors, including financial institutions, are demonstrating in their compliance with stringent cybersecurity regulations.
Non-compliance with these regulations can result in severe penalties, including hefty fines and reputational damage. Therefore, it’s crucial for financial institutions to understand and adhere to these regulations.
One such act is the Gramm-Leach-bliley Act (GLBA) or the Financial Services Modernization Act of 1999. Due to its rigorous standards for protecting customers’ records, this act has considerably altered how financial establishments take care of data safety.
This article will discuss the penetration testing for GLBA compliance from a cybersecurity perspective. Its recent additions in 2022, and, more importantly, the importance of penetration testing and vulnerability scanning for compliance with the new changes to GLBA’s Safeguard Rule.
What is GLBA?
In the realm of cybersecurity, GLBA‘s primary role is to ensure that financial institutions protect and maintain the confidentiality of their clients’ nonpublic personal records (NPI). This protective function, which covers any personally identifiable statistics collected from a purchaser while providing a monetary product or service, or such records submitted to the institution via some other business enterprise, instills a sense of security and reassurance among customers.
The GLBA is enforced and regulated using numerous groups, the Federal Trade Commission (FTC) in general but also involving the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Office of Thrift Supervision (OTS).
Instead, it mandates economic institutions to consider their duration, complexity, nature, scope of activities, and the sensitivity of the consumer facts they possess, even as they formulate their security programs. It stresses the need for a threat management strategy that determines reasonably foreseeable risks, ensures the adequacy of present safeguards, and periodically monitors and checks them.
Although financial institutions’ business activities complicate the GLBA and involve various details, the subject would focus on its aspects concerning security assurance and pen testing, that is, the standards under its Safeguard Rule. Financial institutions should implement stringent standards, such as risk assessments, security programs, and employee education, to attain GLBA compliance.
The Gramm-Leach-Bliley Act divides into several primary components, each of which plays a crucial part in protecting customer information and private financial information:
GLBA compliance – Safeguards Rule
The Safeguards Rule does not issue one-size-fits-all instructions. Instead, it mandates financial institutions to consider their size, complexity, nature, and scope of activities, as well as the sensitivity of the customer information they possess, while formulating their security programs. It stresses the need for a risk management strategy that determines reasonably foreseeable risks, ensures the adequacy of existing safeguards, and periodically monitors and tests them.
The function of penetration testing in GLBA compliance
Penetration testing, a critical component of protecting customer information, is a vital issue of technical safeguards within the GLBA’s Safeguards Rule.
Under GLBA compliance, penetration testing consists of a sequence of simulated cyber attacks against an enterprise’s network, device, utility, or typical IT infrastructure to discover potential vulnerabilities.
The purpose behind the checks is to take advantage of vulnerabilities in a completely identical way a cybercriminal would achieve this, with the result being the identification and closure of those vulnerabilities before their exploitation within a real cyber attack.
GLBA penetration testing enables financial institutions to:
- Identify vulnerabilities in their network infrastructure, systems, and applications that may allow unauthorized individuals to gain access to nonpublic personal information.
- Test the effectiveness of their security controls and see if they can hold up against a real cyber attack.
- Comply with regulatory GLBA requirements regarding regularly testing and monitoring the effectiveness of key controls, systems, and procedures associated with information security.
- Establish the efficacy of their information security training by probing whether employees implement security procedures.
- Show due care when protecting sensitive customer data.
By incorporating penetration testing into their cybersecurity approach, financial institutions can guarantee that they’re not only compliance with GLBA but also actively managing cyber risk.
GLBA penetration testing requirements
As the Act was revised in 2021, and enforcement was first scheduled for November 2022 but later moved to June 2023. GLBA has delineated annual penetration testing and frequent vulnerability scanning as compliance requirements.
How should GLBA penetration testing be?
- Scope of testing: The scope of the penetration test should encompass all systems that contain nonpublic personal information stored, processed, or transmitted.
- Frequency of penetration test: According to Section 314.4, penetration testing must be done yearly for GLBA compliance. Yet, cybersecurity best practices in the industry recommend more regular security testing (every quarter, for example) for high-risk systems.
- Frequency of vulnerability testing: Section 314.4 states that vulnerability testing, which can be done through vulnerability scans, is to be conducted every six months. This regulation is the same as the one adopted by PCI DSS, which is a credit card merchant compliance requirement.
- The testing approach for GLBA compliance is thorough, addressing both internal and external systems, and incorporating testing of network and application security controls. This comprehensive approach, while not including social engineering tests and user awareness, instills confidence in the effectiveness of the information security program.
- Remediation and reporting: You must prioritize and classify the found vulnerabilities according to risk level. The team should present a detailed report, highlighting the findings and remediation recommendations. The team must perform a retest after they have remediated the vulnerabilities to ensure practical remediation efforts.
Security Monitoring and Testing
For information systems, monitoring and testing shall include continuous monitoring or periodic penetration testing and vulnerability assessments. In the absence of effective yet constant monitoring or other systems to identify, continuously, changes in information systems that could cause vulnerabilities, you shall perform:
(i) The team determines penetration testing of your information systems annually based on relevant identified risks following the GLBA risk assessment.
At its most basic level, GLBA Penetration testing entails testing hacking attempts to expose possible security vulnerabilities in a system. Here those that store and process financial information. The test mimics actual attacks so that weak spots and vulnerabilities are discovered and can be marked with areas of need for improvement. Its goal is to offer an explicit guide towards increasing an organization’s security level.
Underlying Techniques: Black box, White box, and Grey box testing
The efficiency of GLBA Penetration testing heavily depends on the techniques used, primarily black box, white box, and grey box testing. Black box testing mimics an external attack, where the tester possesses less knowledge of the system. Conversely, in a white box test, the tester is given comprehensive information regarding the system, replicating an insider attack. Grey box testing falls in between, with the tester possessing some knowledge of the system.
Adapting GLBA Penetration Testing to Your Organization
Each firm operates differently and leverages technology differently. Thus, the response to GLBA Penetration testing must be similarly attuned to accommodate this difference. For instance, a bank can prioritize more transaction systems, whereas an investment company can emphasize customer data systems. Despite the specifics, the chief concern is to facilitate the security and compliance of confidential consumer information.
Collaborating with GLBA Penetration Testing Experts
Successful GLBA Penetration testing involves in-depth information about present-day hacking techniques and the mindset of an attacker. Therefore, it is a great idea to collaborate with skilled third-party companies that’ve expertise in this field. These third-party vendors introduce in-depth knowledge that could strengthen your company’s protection stance and compliance.
GLBA Penetration Testing: Adapting With Your Systems
It’s important not to forget that GLBA Penetration testing is not a one-time job. As the generation evolves and cybercriminals become smarter, so should your technique for security testing. Regularly scheduled testing ensures that your structures are updated against continually evolving threats.
Creating and Maintaining Great Documentation
Documentation is a key part of GLBA Penetration testing. Not only does it provide a snapshot of your security posture at different points in time, but it also helps demonstrate compliance to auditors. The document should outline everything from your testing criteria to identified vulnerabilities and actions to address them. Thorough and clear documentation is a crucial output of any GLBA Penetration testing exercise.
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Conclusion
Compliance with Gramm-Leach-bliley Act (GLBA) is vital to any business enterprise. Organizations must conduct penetration checks to comply with GLBA, but they are merely an enterprise’s cybersecurity initiative. A powerful information protection application, mandated by the Act, must encompass a multi-layered method of security, a practical written hazard assessment an incident response plan, which integrates administrative, technical, and physical protection for the confidentiality, integrity, and availability of nonpublic information.
If you want a penetration testing organization with a few years of specialization in penetration testing in the US and Europe. Then reach out to our experts at Qualysec to find out how we can assist with your next GLBA compliance pentest.
GLBA Penetration testing is an imperative factor of the protection policy that business institutions must implement. Utilized effectively, it goes a long way towards mitigating loss through cyber-attack or information breach.
Keep in mind that GLBA Penetration testing must not be achieved as a solitary exercise. But on a regular basis, as generation and organization techniques shift, as does the technology in cybercrime. Always ensure that you retain the correct documentation in case of auditing, and often adjust your testing method to fit your company’s specific needs.
Talk to Our Cybersecurity Experts to see how we help you meet GLBA security standards.
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FAQ
1. Is penetration testing needed under GLBA?
As of June 2023, GLBA requires yearly penetration tests as part of compliance with the regulation.
2. Is vulnerability scanning a requirement under GLBA?
Yes, GLBA requires vulnerability scans and assessments every six months in compliance with requirements.
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