Penetration Testing — Rules of Engagement & Cadence

Owner: Security. Review cadence: per engagement, at least annual.

External penetration testing is a SOC 2 / FedRAMP expectation and the highest- signal validation of the technical controls in SECURITY.md. This document is the standing RoE to hand a testing firm; engaging the firm and scheduling the test is an organizational action (see Procurement).

Cadence

Scope

Targets:

Emphasis areas (where our threat model concentrates risk):

Out of scope: subprocessors (Stripe/Resend), volumetric DoS, and findings requiring a pre-compromised operator cluster.

Environment & rules

Findings → remediation

Findings map onto the standard remediation SLA (Critical 24h / High 1 week / Medium 1 month / Low 3 months — SECURITY.md). Each finding gets a tracked ticket; criticals are re-tested before the engagement closes. The final report is retained as SOC 2 evidence (see soc2-evidence-map.md, CC4.1).

Vendor selection criteria

When picking a testing firm, the Security lead evaluates against:

Tie-breaker on otherwise-equal candidates: a firm that publishes anonymized case studies + recent CVEs they've credited reporters on.

Expected deliverables

Each engagement closes with these artifacts; failure to deliver any blocks sign-off and the second tranche of payment:

Findings track + retest workflow

  1. Security lead ingests the findings into the same workflow as CI / Dependabot advisories (one ticket per finding).
  2. Severity-driven SLA from SECURITY.md § Vulnerability management applies.
  3. Each finding's ticket links back to the engagement id + the firm's raw-evidence reference.
  4. Critical / High findings get a retest from the same firm after remediation, before the engagement closes.
  5. Medium / Low findings are retested internally; the firm signs off on the close-out summary.

Report retention

Pentest reports are Restricted artifacts per the InfoSec policy § 3. Stored in the company password manager (not the repository). Retention per the data retention policy under the legal-obligation exception: 7 years to support SOC 2 / FedRAMP / regulator follow-on review windows.

Annual program review

Security lead reviews the program once per fiscal year:

Review notes are committed alongside the year's annual training log.

Procurement (the human steps)

  1. Select a reputable firm against the criteria above; sign an MSA + NDA
  2. Share this RoE + read-only access to SECURITY.md and the architecture overview in README.
  3. Schedule the window; stand up the staging cluster + seed test orgs.
  4. On delivery: ingest findings into the remediation workflow, re-test criticals, file the report in the password manager as evidence, update the soc2-evidence-map CC4.1 row with the engagement date.

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