CMMC Archives

Pen Testing versus Vulnerability Assessment

Feeling confused about security assessments? Are you unsure if a Vulnerability Assessment or Penetration Test is the right assessment for your organization? While both aim to test your defenses and security postures, they take very different approaches. This blog will untangle the mysteries of Vulnerability Assessments and Penetration Testing, helping you choose the ideal champion to evaluate your security posture.

Vulnerability Assessments (VAs) leverage automated tools to scan for known vulnerabilities in your software and systems. They provide a high-level view of potential issues based on documented weaknesses. This approach is cost-effective and efficient, making it ideal for regular checkups.

Penetration Testing (PT) simulates real-world attacker behavior, actively exploiting existing vulnerabilities to measure their impact. This in-depth assessment reveals how attackers might gain access and cause damage. However, Penetration Tests are more complex, requiring specialized skills and manual effort, leading to higher costs.

Organizations look for these security assessments usually for legal, contractual or regulatory purposes. Once you understand the business objective(s) for your assessment, you can select the right option or probably conduct both tests. However, in our experience as cybersecurity professionals for over 12 years, leveraging the strengths of both VA and PT at different times is ideal for your cybersecurity strategy.

Comparing Pen Testing and Vulnerability Assessment

Vulnerability Assessment and Penetration Testing (Pen Testing) are both critical components of a comprehensive cybersecurity strategy, but they serve different purposes and have distinct methodologies. Here’s a comparison of the two:

1. Purpose

Vulnerability Assessment: The primary goal of a vulnerability assessment is to identify, assess, and categorize vulnerabilities in an organization’s systems, networks, and applications. It focuses on finding weaknesses in the security posture without exploiting them. It aims to provide a snapshot of potential weaknesses that could be exploited by attackers.

Pen Testing: Pen Testing, on the other hand, involves actively simulating real-world cyberattacks to exploit vulnerabilities and determine the extent to which an attacker can gain unauthorized access or compromise systems. The primary purpose is to evaluate an organization’s security posture and measure its ability to withstand attacks if they are attacked.

2. Scope & Frequency of Testing

Vulnerability Assessment: It usually has a broader scope, focusing on identifying as many vulnerabilities as possible, including low-risk ones. It provides a comprehensive list of potential weaknesses.

Pen Testing: Pen testing has a narrower scope and typically focuses on a specific target or set of targets. It aims to demonstrate the impact of exploited vulnerabilities and assess the overall security posture.

3. Methodology

Vulnerability Assessment: It typically involves automated or manual scans of systems and networks to identify known vulnerabilities. The assessment can include vulnerability scanning tools, configuration reviews, and system analysis.

Pen Testing: Pen testing involves ethical hackers (penetration testers) actively trying to exploit vulnerabilities to understand their potential impact and determine if unauthorized access or data breaches are possible. This may include attempting to gain unauthorized access, privilege escalation, social engineering, network probing, data exfiltration, or other attack scenarios.

4. Reporting

Vulnerability Assessment: The output of a vulnerability assessment is a list of identified vulnerabilities, their severity ratings, and recommendations for remediation. It provides a roadmap for improving security but doesn’t include detailed exploitation scenarios.

Pen Testing: Pen testing reports include information on the vulnerabilities exploited, the impact of successful attacks, the techniques used, and recommendations for mitigating the risks. These reports are more in-depth and provide actionable insights based on actual attack simulations.

5. Regulatory Compliance

Vulnerability Assessment: Vulnerability assessments are often almost required to comply with various regulations and standards, such as PCI DSS, ISO 27001, SOC 2, HIPAA, NIST Cybersecurity Framework, NIST 800-171, CMMC 2.0, etc. This is considered as the minimum required security program for several organizations.

Pen Testing: Penetration testing is also required, at times, by regulations and security standards, and it is more focused in the areas where customer data is stored. Organizations in the finance industry, product/cloud companies and the healthcare sector are required to conduct the pen testing as the cost of breaches is too high if the services/products are not secured properly. Pen testing is required in any certification audit including SOC 2 & ISO 27001, apart from several compliance standards including PCI DSS, HIPAA, NIST Cybersecurity Framework, NIST 800-171, CMMC 2.0, etc.

6. Cost & Time

Vulnerability Assessment: Typically carried out through automated processes, this operation can take anywhere from a few hours to several hours to complete. The process, which includes identifying vulnerabilities and validating the results, is generally completed within a few days. The cost for this engagement usually begins at around USD 2,500.

Pen Testing: A considerable amount of work goes into collecting public information, conducting analysis, identifying vulnerabilities, and executing exploitation, including privilege escalation. Depending on the type of penetration testing – whether it’s network, application, or other asset types – the engagement typically spans 2 to 6 weeks. The cost for these services starts at approximately USD 15,000.

7. Benefit to your Cybersecurity Strategy

Vulnerability Assessment: The assessment tells you how your systems are configured and which policies & procedures you need to be changed to enhance security.

Pen Testing: It tells you how secure your systems are and which security controls are not implemented. After a Pen Test, you need to review your security tech & industry-specific best practices.

Do you need Pen Testing and Vulnerability Assessment or just one?

Vulnerability assessments are focused on identifying vulnerabilities, while penetration testing involves actively exploiting these vulnerabilities to assess their real-world impact. Both approaches are valuable in a comprehensive cybersecurity strategy, with vulnerability assessments providing continuous monitoring and early detection of weaknesses and penetration testing helping organizations understand their readiness to defend against sophisticated attacks. Both are valuable tools in a cybersecurity program, and organizations often use a combination of both to strengthen their overall security posture.

Compliance Driven Decisions: If legal, contractual, or regulatory requirements demand specific assessments, you need to follow the mandated standards or clauses.

Understanding Your Needs: If the decision isn’t dictated by external factors, consider your specific needs. Vulnerability Assessments are excellent for regular scanning and identifying broad areas for improvement. They are cost effective and help you categorize vulnerabilities. Pen Testing is invaluable for uncovering deeper vulnerabilities and understanding their real-world consequences.

How databrackets can help you with Vulnerability Assessment & Pen Testing

Our Vulnerability Assessment & Pen Testing capabilities have been accredited by the A2LA for ISO 17020 Conformity assessment for inspection bodies. Our cybersecurity experts have several years of experience helping organizations across industries to meet regulatory and customer requirements.

Our client engagement starts with your business objective in mind. Vulnerability Assessment & Pen Testing is requested for several reasons:

To secure your environment
To meet certain regulatory compliance or certification requirements
To fulfill a request made by your customer
A combination of the reasons mentioned above

Once we understand what you require, our exercise focuses primarily on scoping of the engagement and setting expectations. We use a variety of tools depending on the type of test and systems in which we need to identify vulnerabilities & conduct pen testing. Our process includes:

Discovery
Identifying and finalizing assets
Identifying vulnerabilities
Exploitation of the vulnerabilities (Pen Testing)
Validation of the issues identified
Remediation/Recommendations
Re-testing

We conduct a wide variety of Penetration Tests for our clients to evaluate the level of security in the following:

Internal Network
External Network
Web Application
Mobile Apps
Cloud Infrastructure
IoT Devices

Apart from using the tools best in the industry, we also focus on remediation and retesting of the environment. We just don’t give hundreds of pages of reports without any help to eliminate the risks. We help our clients prioritize the risks based on the context, patch the systems and select security tech, policies and procedures that are considered best practices in their industry. We also set up continuous monitoring after our tests to track any changes to your environment & send you timely alerts.

As we continue to work with our clients, we sharpen our understanding of your specific environment and system. This helps us to design cadence for continuous protection and monitoring using the right tools to ensure continual improvement and proactive identification of issues for the future. You can contact us for a customized quote or schedule a consultation.

databrackets overview

Our team of security experts has supported organizations across a wide variety of industries to align their processes with security frameworks like ISO 27001:2022, SOC 2, HIPAA, 21 CFR Part 11, NIST SP 800-53, NIST Cybersecurity Framework, NIST SP 800-171, GDPR, CMMC 2.0 etc.

We are constantly expanding our library of assessments and services to serve organizations across industries. Schedule a Consultation if you would like to Connect with an Expert to understand how we can customize our services to meet your specific requirements.

Author: Aditi Salhotra, Digital Marketing and Business Development, databrackets.com

Aditi is a Digital Marketing and Business Development Professional at databrackets.com. She graduated with honors in Marketing from Sheridan College, Canada. In addition to her current profile, she contributes to Product Development and Content Creation. She is a strong advocate of Good Cyber Hygiene and white hat SEO techniques. She is proud of the company’s mission to safeguard organizations from cyber threats and ensure their business continuity in adverse situations.

Technical Expert: Srini Kolathur, Director, databrackets.com

The technical information presented in this blog has been carefully reviewed and verified by our Director, Srini Kolathur. Srini is results-driven security and compliance professional with over 20 years of experience supporting, leading, and managing global IT security, compliance, support, and risk assessment in fortune 100 companies. Some of his key areas of focus are SOC 2, ISO 27001, NIST 800-171, NIST 800-53, NIST Cybersecurity Framework, HIPAA, Security Risk Assessment, CMMC 2.0 among others. He is a CMMC Registered Practitioner (RP), CISSP, CISA, CISM, MBA. He is active in several community groups including Rotary International and TiE.

Top 5 CMMC Implementation Gaps

CMMC is a security framework that is mandatory for contractors who want to work with the Department of Defense (DoD). It is based on the US National Institute of Standards and Technology (NIST) family of standards, specifically on NIST SP 800-171. It was first introduced as a 5-tiered framework in 2020. The next version of the framework, CMMC 2.0, is currently being finalized with a 3-tiered structure and several updates.

Rulemaking for CMMC 2.0 is scheduled to be completed by the end 2023 and it is expected to be part of DoD contracts. Organizations are encouraged to complete the implementation process before the end of 2023, to ensure they can complete the certification process in time to bid for contracts, as this requirement is phased-in during FY 2024.

databrackets and Tego believe that DIB companies / Organizations seeking certification (OSCs) should be made aware of the CMMC implementation gaps, so they are able to avoid them. databrackets is enroute to becoming a CMMC Third Party Assessment Organization (C3PAO), that will conduct CMMC audits and issue the CMMC certificate. This blog is part of our collaborative effort with Tego, a Registered Practitioner Organization (RPO) committed to supporting organizations comply with CMMC 2.0 benchmarks and meet technological and process requirements. We have also jointly presented a webinar ‘Prepare for CMMC 2.0’ to help DIB companies plan their CMMC journey.

CMMC Compliance with an RPO

A Registered Practitioner Organization (RPO) offers consulting services to help you get ready for your CMMC Certification by a C3PAO. To avoid the implementation gaps that you may encounter, let us begin by discussing the CMMC compliance journey, when you work with an RPO.

1. Pre-assessment and Gap Analysis of your existing controls against CMMC requirements
2. Creating a Plan of Action & Milestones (POA&M) to identify the steps and technology you need to address the gaps
3. Cost-benefit analysis of a CMMC Certification
4. Implementation of new controls identified in the POA&M
5. An RPO can help with 1. through 4.
6. C3PAO Assessment and Certification

When you engage the right RPO, and undergo a thorough pre-assessment and gap analysis, you can identify and prioritize your gaps at the outset. This saves time and helps you create plans of action and milestones (POA&Ms) that will ensure you meet CMMC benchmarks. We recommend using the CMMC framework as a risk management tool and a best practice framework as well. Once you correctly identify the gaps and fix them, your RPO should be monitoring your progress and adjusting their assessment of your security posture. Once they confirm that you are ready, you can proceed with the assessment by a C3PAO and get certified.

NIST SP 800-171 Self-Assessment

Sometimes, companies begin their CMMC journey by conducting a self-assessment using NIST SP 800-171. Typically, the scoring is inaccurate and almost always over-favors the controls in their environment. Additionally, the self-assessment may be done by somebody that’s not there anymore or done by one person who hasn’t engaged multidisciplinary inputs that are required for understanding the control environment. An RPO can assess your environment more accurately because CMMC 2.0 includes additional security requirements that go beyond the scope of NIST 800-171. It is important to note that identifying what you’ve done so far to evaluate yourself is a huge step forward when you undergo a pre-assessment. This not only shows maturity but also helps them when they engage an RPO.

Cost of CMMC Implementation

The cost to implement CMMC 2.0 controls depends on the size and complexity of your organization. In general, the cost depends on the scope and the controls you need to implement. The cost of the report by the RPO depends on the scope and assets while the cost of the additional controls you need to implement will depend on your environment. The best way to manage the cost is to engage an RPO and analyze your specific environment to get an idea of what the cost will be. You need to make sure there’s a business case for it, particularly if you plan to comply with CMMC 2.0 Level 2. There needs to be a reckoning with your business model. During your pre-assessment, you need to identify if it’s worth continuing business in the DIB because it is going to be a substantial investment.

Engaging with a C3PAO

As you move through that POA&M process, if they have been written correctly, you will be able to estimate when you will meet your milestones and be ready to engage a C3PAO. You don’t have to have them completed before you engage the C3PAO. In fact, as you’re moving through the plans of action with still some open, it’s recommended that you try to engage the C3PAO without losing time. When the rulemaking is finished and CMMC certification becomes a requirement, there’s going to be a rush on getting appointments with a C3PAO. Working with a good RPO can help you manage your compliance process and get confident about meeting your milestones.

Time required to comply with CMMC

While the journey to becoming CMMC compliant seems extensive, the total time required depends on the organization and whether you are aiming for CMMC Level 1 or Level 2. The total time required also depends on the size of your organization, how complex your systems are and how much Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) you have in their environment. Some organizations only need to comply with Level 1 because they just have FCI. Others have CUI in very managed locations. Your RPO should be validating these elements and once you’re able to identify where your CUI is, you can estimate the time it would take your organization to comply with CMMC standards. Level 1 compliance may take 2-4 months and Level 2 may take longer since it has many more controls.

Top 5 Implementation Gaps for CMMC

Understanding these nuances of the process, will help you understand the top five implementation gaps for CMMC

CMMC 2.0 Standards: Understanding the actual operational requirements to meet the CMMC standards.
System Security Plan: Establishing a suitable System Security Plan to meet CMMC compliance requirements.
Risk Management Plan: Developing a comprehensive data security and risk management plan.
Implementation: Securing the IT infrastructure and implementing the necessary security controls.
Training: Educating and training users on proper security practices and procedures.

Few organizations invest time and resources to understand their operations, track where CUI is and try to manage it. The key is in understanding how protected information moves through your environment. There are a lot of ways to do it. Tego interviews various stakeholders from the organization. A roundtable discussion of who’s using CUI is always the best place to start. This includes the person who did the NIST 800-171 scoring, HR, the Heads of the lines of business, etc. RPOs also employ various tools that help you identify and then mark the CUI in your environment over time. This is critical since protected information enters and exits your environment and you need to identify where it is in your CRM, in your unstructured data etc. Most of those tools also offer additional security that can complement control requirements in CMMC.

The next critical point is establishing a suitable System Security Plan. Some organizations use NIST 800-171 to complete a self-assessment, but they don’t really embrace the framework through which they want to manage their risk. The SSP is a comprehensive plan that outlines an organization’s approach to securing its systems and protecting its sensitive information. It is a key component of the CMMC assessment process and is required for all CMMC certification levels.

The SSP must be prepared and maintained by the organization seeking CMMC certification, and it must address all aspects of the organization’s security posture, including physical security, access controls, incident response, network security, and system configuration. The SSP must also include detailed information on the organization’s cybersecurity policies, procedures, and practices, as well as any third-party service providers used by the organization. The SSP addresses completeness and eliminates big gaps. For example, if you have a network administrator do the NIST 800-171 score without complete awareness of where CUI was, which is the number one gap, you end up having organizations that lack actual alignment with NIST 800-171. We have seen a lot of things on paper where the organization hasn’t really embraced the comprehensive data security and risk management plan. Within those controls, are actions that you need to take and things you need to do. Organizations who want to be CMMC compliant, need to run a secure organization based on that framework.

Organizations also tend to have compliance gaps because of budgeting. Complying with NIST 800-171 and CMMC is an opportunity for organizations to refresh their security infrastructure. We have seen some neglect in this area with regard to investment in tools. Organizations need to take the time to invest in this critical update. We have had tough conversations about the cost because it can become very expensive. Planning to work with the DoD forces organizations into making an investment in their security infrastructure, to become CMMC compliant.

Lastly, educating and training security users or training users in security practice is important. Users are always the number one risk in any organization, in any context. We have seen this being neglected or lacking in organizations. Training needs to go beyond just doing phishing campaigns and an annual security awareness training.

We would also like to mention that some organizations will endeavor to manage CMMC compliance over time. While, it is still recommended to maintain a relationship with your RPO in an advisory context, some organizations may want to manage day-to-day compliance with internal staff. In that case, it is recommended they get some staff members CCP Certified. Organizations can get that training through our partners. In addition to that, there are some things that may not require a CCP from the operation side where you want individuals such as a network admin to be schooled on the specific requirements that you need for network security, and we can also offer those trainings as pursuant to the requirements in CMMC.

Without having CMMC compliance, you will ultimately be precluded from participating in contracts as a subcontractor or prime in the DIB. So, you’re going to have to invest your time and resources in the requirements if there’s a business case for it and embrace the fact that there’s going to be money spent. Aside from the risk of losing DoD contracts, this is a best practice framework. Alignment to it and following CMMC certification standards reduces risk in your environment too. So, there are more benefits to comply with it, apart from the revenue that could come from a DoD contract.

Engaging with an RPO for your certification efforts is recommended because the RPO has invested the time and energy to understand the specifics of CMMC and its requirements. Doing that pre-assessment gap analysis is the way to prioritize what you need to do both for certification and for risk reduction. As an RPO, Tego offers technical mitigations, which they are suited for because they are an IT professional services organization, capable of helping with a security infrastructure refresh. They’re also available to help implement controls such as network segmentation, the hardware upgrades, server OS upgrades. They extend their support with all of these under the management of the CMMC Registered Practitioners (RPs) that are on staff at Tego.

Co-Author : Greg Manson

Greg is the Vice President of Security, Audit and Compliance at Tego. He is an ISACA Certified Information Systems Auditor (CISA) and a Certified Data Privacy Solutions Engineer (CDPSE). He is a Registered Practitioner (RP) and Tego is a Registered Provider Organization (RPO). He assists many customers in the Defense Industrial Base navigate the strict requirements of the Defense Acquisition Regulations Supplement (DFARS).