Physical penetration tests are an excellent and often overlooked way to test an organization's security posture. However, they can come with serious consequences for testers if they aren't properly prepared. Look no further than the recent arrest of two pen testers probing Iowa's Dallas County courthouse security.
According to a September 13 report in the Des Moines Register, the men were employed with Coalfire, a cybersecurity adviser with headquarters in Colorado, and outfitted with "numerous burglary tools." They told authorities they were "hired to test out the courthouse alarm system's viability and to gauge law enforcement's response time, an alleged contract that Dallas County officials said they had no knowledge of...."
The Register reported:
Authorities later found out the state court administration did, in fact, hire the men to attempt "unauthorized access" to court records "through various means" in order to check for potential security vulnerabilities of Iowa's electronic court records, according to Iowa Judicial Branch officials.
But the state court administration "did not intend, or anticipate, those efforts to include the forced entry into a building," a Wednesday news release from the Iowa Judicial Branch read.
Coalfire, in a September 18 press release, said that the company and the Iowa State Court Administration "believed they were in agreement regarding the physical security assessments for the locations included in the scope of work. Yet, recent events have shown that Coalfire and State Court Administration had different interpretations of the scope of the agreement." The statement further noted that both parties plan to conduct independent reviews and release the contractual documents executed between both parties
Obviously, there are many sides to this story, and more will come out. In the meantime, here are six lessons learned from my own experience conducting physical penetration testing:
1. Get It in Writing
Out of the gate, define the rules of the engagement (ROE) in as much detail as possible. You don't want to find yourself in a holding cell wondering why "various means" didn't give you carte blanche to break in. The statement of work (SOW) also needs to specifically define what you're going to be testing, what you are trying to access or accomplish, and how. Remove as much ambiguity from the ROE and SOW as possible; otherwise, the engagement and its results will be left to interpretation rather than hard facts.
Furthermore, there needs to be indemnification language in the SOW that covers when you've been given bad scope information from the client. Assume that if it can go wrong, it will, and then cover it here.
During physical assessments, we suggest having the client first conduct a "dry run" of your approach to see what problems occur. We also have their signatory authority review the operation order (OPORD) and approve it, paying special attention to the avenues of approach or the concept of operations (CONOPS) in how the engagement will be executed. That way, things like whether "forced physical entry has been authorized" will never be an issue, which is in the mutual best interest of all.
2. Take Your Paperwork with You
When doing physical penetration testing, our consultants carry the basic equivalent of a "get out of jail free" card. In most cases, that means a signed letter of permission with legally binding language allowing them to be doing exactly what they are doing. Having copies of the OPORD and ROE aren't bad ideas either.
3. Have a Dedicated Point of Contact During Testing
It's imperative that somebody is available to keep a misunderstanding from escalating into something worse. The key is to have multiple ways to resolve problems if things go bad. If nothing else, your own contacts need to know what's going on.
It's also important to ensure that you have properly planned your engagement. We use the PACE approach — having Primary, Alternate, Contingency, and Emergency plans of action throughout our engagements. Chances are, a properly planned engagement may still have some drift, but knowing whom to contact and when can save you from a lot of grief — getting arrested or worse.
4. Go Further if You Can
If possible, inform local law enforcement, in advance of the testing, about what you will be doing, and provide them with signed permission from your client. If not out of scope, make sure the facilities and/or physical security heads know about your testing plans, too. It matters.
5. Understand What You're Walking Into
You need to understand your client's escalation and response procedures. There are certain situations during physical pen testing against critical infrastructure or other secure facilities when someone breaking in, even if conducted during an authorized test, will trigger response actions and will still be considered a compliance violation such as, for example, critical infrastructure protection standards from the North American Electric Reliability Corporation, a nonprofit international regulatory authority over Canada, United States, and Mexico. Due to these special considerations, we make arrangements to be greeted on the other side by an observer who is "escorting" us from a distance, so we aren't in violation of any federal laws or regulatory requirements.
Each situation is unique, and all factors need to be considered. For instance, commercial facilities that frequently receive threats of violence, and/or have increased risk of terrorist attacks may have their physical security personnel armed. Understand the dangers before you go in, what regulations you might violate, and get in sync with your client on handling complexities when they arise.
6. Know Your Exposure
Ultimately, it's not on the client to protect you. It's on you to protect both yourself and the client. From a legal perspective, you want to know whether your errors and omissions/professional liability insurance has coverage for these kinds of situations. You want to make sure both liability and indemnification calls out how general situations of scope breach are handled and define some baseline rules. And you want to understand the difference between negligence and gross negligence.
It's important to go to great lengths to define your engagements with clients to include scope and authorized versus unauthorized actions. All engagements are partnerships, and by providing clear and proactive communication, you can ensure the best outcome for all parties involved.
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