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TDA-09.5: Application Penetration Testing

TDA 9 — Critical Detect

Mechanisms exist to perform application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS).

Control Question: Does the organization perform application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS)?

General (17)
Framework Mapping Values
CIS CSC 8.1 16.13
CIS CSC 8.1 IG3 16.13
CSA CCM 4 AIS-05 TVM-06
CSA IoT SCF 2 SDV-07 SET-02 SET-04 SET-06
NIST 800-53 R5 (source) SA-11(5)
NIST 800-53 R5 (NOC) (source) SA-11(5)
NIST 800-218 PW.7 PW.8
OWASP Top 10 2021 A01:2021 A02:2021 A03:2021 A04:2021 A05:2021 A06:2021 A07:2021 A08:2021 A09:2021 A10:2021
PCI DSS 4.0.1 (source) 6.2.4
PCI DSS 4.0.1 SAQ A-EP (source) 6.2.4
PCI DSS 4.0.1 SAQ C (source) 6.2.4
PCI DSS 4.0.1 SAQ D Merchant (source) 6.2.4
PCI DSS 4.0.1 SAQ D Service Provider (source) 6.2.4
SWIFT CSF 2023 7.3A
SCF CORE Mergers, Acquisitions & Divestitures (MA&D) TDA-09.5
SCF CORE ESP Level 2 Critical Infrastructure TDA-09.5
SCF CORE ESP Level 3 Advanced Threats TDA-09.5
US (6)
Framework Mapping Values
US C2M2 2.1 ARCHITECTURE-4.H.MIL3
US DHS CISA TIC 3.0 3.UNL.STEXE
US HIPAA HICP Large Practice 7.L.A
US IRS 1075 SA-11(5)
US TSA / DHS 1580/82-2022-01 III.F.2.c
US - CA CCPA 2025 7123(c)(6)
EMEA (4)
Framework Mapping Values
EMEA Germany C5 2020 PSS-02
EMEA Israel CDMO 1.0 11.9 17.3 17.15 17.17
EMEA Saudi Arabia ECC-1 2018 1-6-3-3
EMEA Saudi Arabia SACS-002 TPC-72
APAC (3)
Framework Mapping Values
APAC Australia ISM June 2024 ISM-0402
APAC New Zealand NZISM 3.6 14.5.6.C.01
APAC Singapore MAS TRM 2021 6.1.6

Capability Maturity Model

Level 0 — Not Performed

There is no evidence of a capability to perform application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS).

Level 1 — Performed Informally

C|P-CMM1 is N/A, since a structured process is required to perform application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS).

Level 2 — Planned & Tracked

Technology Development & Acquisition (TDA) efforts are requirements-driven and governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist:

  • Development and acquisition management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
  • IT/cybersecurity personnel identify cybersecurity and data protection controls to address applicable statutory, regulatory and contractual requirements for technology development and acquisition management.
  • IT/cybersecurity personnel implement secure practices to protect the confidentiality, integrity, availability and safety of the organization's technology assets, data and network(s).
  • Secure development practices mostly conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.).
  • Procurement practices require third-party developers of systems, system components or services to follow secure engineering practices.
  • A Project Management Office (PMO), or project management function, enables the implementation of cybersecurity and data privacy-related resource planning controls across the System Development Lifecycle (SDLC) for all high-value projects.
  • Security engineering, or a similar function, performs application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS).
Level 3 — Well Defined

Technology Development & Acquisition (TDA) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity and data protection controls to protect the confidentiality, integrity, availability and safety of the organization's applications, systems, services and data for technology development and acquisition. o Ensures the Information Assurance Program (IAP) evaluates applicable cybersecurity and data protection controls as part of “business as usual” pre-production testing. o Operates the Cybersecurity Supply Chain Risk Management (C-SCRM) program to identify and mitigate supply chain-related risks and threats.

  • Secure development practices conform to industry-recognized standards for secure engineering (e.g., OWASP, NIST SP 800-218, NIST SP 800-160, etc.).
  • A procurement team, or similar function, ensures that third party development and/ or acquisitions meet, or exceed, the organization's business, cybersecurity and data privacy requirements to have secure and resilient systems, applications, services and processes.
  • A Software Assurance Maturity Model (SAMM) governs a secure development lifecycle for the development of systems, Technology Assets, Applications and/or Services (TAAS).
  • Administrative processes exist and technologies are configured to implement secure configuration settings by default to reduce the likelihood of software being deployed with weak security settings, putting the asset at a greater risk of compromise.
  • An IT Asset Management (ITAM) function, or similar function, categorizes devices according to the data the asset stores, transmits and/ or processes and applies the appropriate technology controls to protect the asset and data.
  • A formal Change Management (CM) program help to ensure that no unauthorized changes are made, all changes are documented, services are not disrupted and resources are used efficiently.
  • A Governance, Risk & Compliance (GRC) function, or similar function;
  • A Project Management Office (PMO), or project management function, enables IAP pre-production testing of cybersecurity and data protection controls as part of the organization's established project management processes.
  • Security engineering, or a similar function, performs application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS).
Level 4 — Quantitatively Controlled

Technology Development & Acquisition (TDA) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist:

  • Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
  • Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
  • Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
  • Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
  • Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
  • Both business and technical stakeholders are involved in reviewing and approving proposed changes.
Level 5 — Continuously Improving

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to perform application-level penetration testing of custom-made Technology Assets, Applications and/or Services (TAAS).

Assessment Objectives

  1. TDA-09.5_A01 the developer of the system, system component, or system service is required to perform penetration testing per an organization-defined breadth.
  2. TDA-09.5_A02 the developer of the system, system component, or system service is required to perform penetration testing per an organization-defined depth.
  3. TDA-09.5_A03 the developer of the system, system component, or system service is required to perform penetration testing under organization-defined constraints.
  4. TDA-09.5_A04 the developer of the system, system component or system service is required to perform attack surface reviews.

Evidence Requirements

E-TDA-03 Application Security Testing (AST)

Documented evidence of application security testing (e.g., DAST, SAST, fuzzing, etc.).

Technology Design & Acquisition

Technology Recommendations

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