Overview In the last 30 days, the FedRAMP Program Management Office (PMO) has published guidance for both vulnerability scanning and penetration testing. The updated guidance comes on the heels of PCI mandating the enhanced penetration testing requirements within its requirement 11.3 as part of the 3.0, now 3.1, version of the DSS. These augmented PCI requirements, introduced in the fall of 2013, took effect on June 30th. For many cloud service providers this means the requirements for vulnerability scanning and penetration testing are more thorough and will require additional resources for planning, executing and remediating findings. This article will walk through the updates and discuss the differentiation between FedRAMP and the PCI Data Security Standard (DSS).

With proper design, implementation and maintenance, periodic user access reviews can be an effective tool for service organizations in achieving their security and compliance goals.

Periodic reviews of system access are critical for service organizations who wish to maintain strong internal control around information security. Access privileges to systems or physical locations that impact the customer’s business environment should be commensurate with the requirements of the services provided. These privileges should also facilitate segregation of incompatible duties. For example, in order to segregate incompatible duties, a system developer generally should not also have access to migrate changes to the production environment.

Effective January 1, 2002, the Institute of Internal Auditors (IIA) released updated standards in the International Professional Practices Framework (IPPF). Internal auditing departments, according to Standard 1312 of the IPPF, must complete an external assessment once every five years from a qualified independent assessor or assessment team. In addition, the chief audit executive (CAE) must discuss the form and frequency of external assessments and the qualifications and independence of the external assessor or assessment team with the board of directors. Standards (unlike practice advisories, practice guides and position papers) are principal focused mandatory requirements consisting of statements for the professional practice of internal auditing and for evaluating the effectiveness of performance which are applicable at the organizational and individual levels.