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Certus Security
Standards first. Certus Security tests only authorised systems, so a written scope and rules of engagement are signed first.

Standards note

GLBA penetration testing under the FTC Safeguards Rule

GLBA penetration testing became explicit when the FTC updated its Safeguards Rule. So many non-bank financial institutions now need annual penetration tests, unless they monitor continuously.

  • Written scope and rules of engagement
  • PTES, OWASP and NIST SP 800-115
  • Nothing retained after close
Glba penetration testing: confirm coverage, test annually and keep the record

Who GLBA penetration testing applies to

The Gramm-Leach-Bliley Act covers financial institutions broadly. However, the FTC Safeguards Rule applies to non-bank institutions under FTC jurisdiction. For example, mortgage brokers, tax preparers and some fintech firms.

Banks follow their own regulators' guidance. Therefore check which rule applies before scoping.

What the Safeguards Rule asks for

The updated rule names testing directly. Also, it offers an alternative for organisations with continuous monitoring.

ActivityExpectation
Penetration testingAt least annually, based on risk assessment
Vulnerability assessmentsAt least every six months
After material changesAdditional testing as needed
Continuous monitoringAn alternative to periodic testing

GLBA penetration testing readiness check

Tick what is in place.

Your result appears here as you tick, so you can see what is still open.

Scoping GLBA penetration testing

Scope follows customer information. So systems that store or process it come first.

  • Customer portals and applications
  • Internal networks holding customer data
  • Remote access paths
  • Cloud environments
  • Connections to service providers

Evidence and reporting

The rule also expects reporting to the board or a senior officer. Because the qualified individual must report at least annually, test results feed that report. As a result, findings reach decision-makers.

In addition, keep remediation records with each report. The rule text is on the FTC Safeguards Rule page.

How Certus works

Every engagement follows a written scope, PTES and NIST SP 800-115. Full engagements usually settle between $35,000 and $120,000, and the floor is $25,000. The bounded Security Posture Assessment starts at $4,500. Its fee is credited in full against a full engagement commissioned within ninety days.

Also review service providers. Because the rule expects oversight of providers with access to customer information, their testing evidence matters too. So ask key providers how they test, and keep their answers on file.

GLBA penetration testing questions

Is GLBA penetration testing required annually?

Under the FTC Safeguards Rule, yes, unless you use continuous monitoring.

Does GLBA penetration testing apply to banks?

Banks follow their own regulators' guidance, which also expects testing.

What else does GLBA penetration testing sit alongside?

Vulnerability assessments at least every six months.

Who receives the results?

The qualified individual, who reports to the board or a senior officer.

Related guides

Scope GLBA penetration testing properly

Describe the systems that hold customer information. We return a written scope that names each standard, with a fixed fee. Nothing is tested before the owner signs.

Request a written scope