Healthcare Penetration Testing: Protecting Patient Data in a Digital NHS

Introduction

Healthcare has rapidly become one of the most targeted sectors for cybercrime. Hospitals, GP practices, and trusts store vast amounts of sensitive data, from electronic medical records (EMRs) to insurance and payment details. The NHS in the UK, along with organisations following HIPAA regulations abroad, face the dual challenge of protecting patient data while delivering seamless digital care.

Penetration testing is no longer optional in healthcare. It is a critical measure to proactively identify, exploit, and fix vulnerabilities before malicious actors can. This blog explores the essential components of healthcare penetration testing, with a specific focus on NHS systems, HIPAA considerations, EMR attack surfaces, and the growing risks of remote access.

Section 1: Understanding Healthcare Data Regulations (NHS & HIPAA)

What Is HIPAA and How Does It Affect Penetration Testing?

HIPAA (Health Insurance Portability and Accountability Act) governs how patient data is handled in the United States. Organisations handling protected health information (PHI) are required to conduct regular risk assessments, which often include penetration tests.

Key HIPAA considerations:

• Identify vulnerabilities in electronic systems

• Ensure encryption and access controls are in place

• Log and monitor all access to PHI

• Protect against reasonably anticipated threats

NHS Data Security and the DSP Toolkit

In the UK, the NHS relies on the Data Security and Protection Toolkit (DSPT) to ensure patient data is handled correctly. Organisations must demonstrate compliance with the National Data Guardian's 10 Data Security Standards. Penetration testing plays a key role in validating the technical and organisational measures outlined by DSPT.

Pen testing can support:

• Secure configuration of systems
• Risk mitigation for data-sharing platforms
• Validation of role-based access to patient records

Including routine penetration tests in your DSP Toolkit response shows that your trust or provider is serious about digital resilience.

NHS Data Security and the DSP Toolkit: How Penetration Testing Supports Compliance

Data protection in healthcare is more than a best practice, it is a legal, ethical, and operational obligation. In the UK, the NHS Data Security and Protection Toolkit (DSPT) forms the cornerstone of compliance for any organisation that handles NHS patient data. Whether you're a hospital trust, private care provider, GP surgery, or third-party supplier, demonstrating your adherence to the National Data Guardian’s 10 Data Security Standards is a mandatory annual requirement.

Among the many technical controls outlined in the DSP Toolkit, one stands out as both critically important and frequently overlooked: penetration testing. While the DSPT sets out broad data security principles, it is up to individual organisations to validate their controls in practice. This is where regular, risk-based penetration testing becomes a vital component in demonstrating compliance and operational readiness.

The Data Security and Protection Toolkit

The Data Security and Protection Toolkit is an online self-assessment tool used by all organisations processing NHS patient data. It ensures that health and care organisations meet national data protection laws, including UK GDPR, the Data Protection Act 2018, and NHS-specific requirements.

At the core of the DSP Toolkit are the 10 Data Security Standards set out by the National Data Guardian (NDG). These standards provide a practical framework for handling data securely, safeguarding against cyber threats, and maintaining patient trust. Key areas include data sharing, access controls, staff training, incident response, and secure technology configuration. Importantly, the DSP Toolkit is not optional. It must be completed annually and is reviewed by NHS England, CQC (Care Quality Commission), and ICS bodies. Organisations that fail to meet the standards risk losing access to NHS data, face regulatory penalties, and may be considered non-compliant under contractual or legal obligations.

While the DSP Toolkit mandates that organisations have “up-to-date, secure technology” and demonstrate “effective cyber risk management,” it does not explicitly name penetration testing in every standard. However, penetration testing plays a crucial role in validating many of the controls that underpin DSPT assertions.

DSP Toolkit compliance 

DSP Toolkit compliance is essential, but it should be the minimum standard, not the goal. Patients trust healthcare providers with their most intimate data, from diagnoses and treatment plans to test results and mental health records. Any breach undermines that trust and can cause long-term reputational harm. NHS Digital and NHS England have consistently warned that the health sector is a top target for cyberattacks.

 The 2017 WannaCry attack that crippled NHS Trusts across England was a watershed moment. Since then, threats have become more targeted, sophisticated, and damaging. Penetration testing offers more than box-ticking. It helps you stay ahead of evolving threats, understand real-world attack paths, protect patient data with evidence-based defences, and build digital resilience across all clinical and non-clinical functions.

Including regular penetration tests in your DSPT submission signals that your organisation takes data protection seriously, invests in proactive cyber defence, understands the difference between policy and practice, and is committed to transparency and improvement. The frequency of testing should be based on risk and environment.

At a minimum, Cybergen recommends annual external and internal penetration testing for all NHS-connected systems, pen testing before launching any new digital service or EMR system, follow-up testing after significant infrastructure or software changes, and testing for third-party suppliers or digital health startups connected to NHS platforms. For healthcare organisations managing multiple sites, cloud services, or clinical portals, penetration testing should be built into your broader continuous security testing strategy, not treated as a once-a-year checkbox.

Section 2: The Rise of EMR-Focused Cyber Attacks

Why EMRs Are High-Value Targets

Electronic Medical Records (EMRs) are among the most valuable data sets for attackers. Unlike credit card data, EMR information cannot be changed or reissued, making it a long-term asset for identity theft, blackmail, or insurance fraud.



Common Attack Vectors on EMR Systems:

• Web application vulnerabilities in patient portals
• Weak authentication and authorisation controls
• Unpatched third-party integrations
• Insecure APIs used for lab or pharmacy data exchange

Penetration testing helps uncover these weaknesses by simulating real-world attack methods. Red and purple team exercises can further test how detection systems and security teams respond to EMR compromise attempts.

Section 3: Securing Remote Access in Modern Healthcare

The Risks of Remote Access in Clinical Settings

With the rise of remote consultations, home-based clinicians, and third-party service providers, remote access has become essential. However, it also introduces significant security risks:

• VPNs misconfigured or shared among staff
• Remote desktop services exposed to the public internet
• Lack of multi-factor authentication (MFA)
• Use of personal devices without endpoint protection

Best Practices for Penetration Testing Remote Access

Healthcare penetration tests should include:

• Credential harvesting simulations
• Brute-force testing against RDP and VPN logins
• MFA bypass techniques
• Device fingerprinting and session hijacking

Assessing remote access controls through active testing allows organisations to close gaps before attackers find them. This is especially critical in hybrid care models where physical boundaries no longer define access zones.

Best Practices for Penetration Testing Remote Access

With healthcare increasingly relying on remote access to support telemedicine, remote diagnostics, and hybrid workforces, securing entry points like VPNs, RDP, and cloud-based portals has never been more critical. Penetration testing provides a controlled and ethical way to uncover weaknesses before malicious actors can exploit them. In healthcare, where patient safety and data privacy are at stake, testing remote access defences should be a routine part of every cybersecurity programme.

Effective healthcare penetration tests should include targeted simulations such as credential harvesting, brute-force login attempts, multi-factor authentication (MFA) bypass testing, and session hijacking techniques. These test scenarios mirror the actual methods used by cybercriminals to breach healthcare organisations, often with devastating results.

One of the most common vulnerabilities uncovered during remote access assessments is weak or reused credentials. Credential harvesting simulations, especially when paired with phishing tactics or data leaked from past breaches, help assess how easily an attacker could gain initial access. Testers may use known credential dumps or create custom phishing lures aimed at helpdesk staff, remote clinicians, or system administrators.

Brute-force testing, particularly on exposed Remote Desktop Protocol (RDP) and VPN endpoints, remains a high-impact technique. Many NHS trusts and private healthcare providers continue to rely on legacy systems or misconfigured gateways with limited lockout mechanisms. During a penetration test, ethical testers simulate repeated login attempts using password spraying or dictionary attacks to test both system resilience and alerting mechanisms.

Multi-Factor Authentication (MFA) is now standard across many healthcare platforms, but not all implementations are equal. A penetration test may attempt MFA bypass techniques such as session token theft, man-in-the-middle proxies, or exploiting fallback mechanisms like SMS codes or security questions. Testing the robustness of MFA policies not only improves compliance but protects high-risk accounts such as those belonging to clinicians, IT administrators, and third-party vendors.

Device fingerprinting and session hijacking tests are also crucial, especially in environments where users log in from a variety of personal and clinical devices. Attackers may attempt to clone sessions, reuse cookies, or simulate trusted devices to gain unauthorised access without triggering alerts. Penetration testing these vectors helps validate whether session management policies and behavioural monitoring tools are functioning as intended.

Ultimately, assessing remote access controls through active testing allows healthcare organisations to identify and close critical security gaps before attackers exploit them. This is particularly important in hybrid care models, where the traditional concept of a network perimeter no longer applies. With staff working from home, community clinics, or third-party partner sites, every remote entry point becomes a potential path to compromise.

Section 4: Key Components of Healthcare Penetration Testing

To be effective, healthcare penetration tests must include both technical and human-factor evaluations:

Key Focus Areas:

• Internal and external network infrastructure
• Web apps including patient portals and booking systems
• Email phishing simulation to test staff awareness
• Wireless security, especially in hospital campuses
• Medical IoT devices (infusion pumps, connected monitors)

The output should include not just a technical report but clear remediation guidance. Prioritisation is critical in healthcare, where system uptime is tied to patient care.

Key Focus Areas in Healthcare Penetration Testing

In a healthcare environment, cybersecurity is not just a technical challenge — it is a patient safety issue. A successful penetration testing engagement must consider the full attack surface, from internal infrastructure and cloud platforms to medical devices and human factors. Prioritising the right focus areas ensures tests deliver maximum impact and enable security teams to take decisive, evidence-backed action.

The first area of concern is the internal and external network infrastructure. These are the core components that connect users, systems, and services. External infrastructure includes internet-facing firewalls, VPN gateways, and web servers, all of which are common targets for initial access attempts. Internal networks, on the other hand, often include flat, unsegmented architectures within hospital sites, which allow attackers to move laterally between systems.

A thorough penetration test evaluates how well these environments are segmented, patched, and monitored for anomalous behaviour. It also identifies default credentials, insecure services, and exposure to known vulnerabilities.

Next is the evaluation of web applications, especially patient portals, appointment booking systems, and prescription platforms. These applications often collect sensitive personally identifiable information (PII), such as NHS numbers, medication history, and home addresses. Healthcare penetration testers use methods from the OWASP Top 10 to assess input sanitisation, authentication controls, and session management. For instance, tests may uncover flaws like cross-site scripting (XSS), insecure direct object references (IDOR), or weak password reset flows, each of which can place patient data at risk.

Another critical element is email phishing simulation. Many successful breaches in the healthcare sector begin with a seemingly harmless email. By simulating realistic phishing campaigns as part of the test, organisations can measure how staff respond to suspicious messages. These simulations help gauge awareness, uncover training gaps, and identify departments or roles most at risk. In highly regulated environments, these tests also help validate DSP Toolkit Standard 3: ensuring that “staff understand their responsibilities” when handling patient data.

Wireless networks, especially in sprawling hospital campuses, are also a vital area for review. Poorly secured Wi-Fi can serve as a launchpad for attackers to access clinical systems or patient records. Penetration tests should include rogue access point detection, WPA2/WPA3 testing, signal bleed assessments, and MAC spoofing attempts. In facilities where BYOD (Bring Your Own Device) is permitted, separate SSIDs, VLAN segmentation, and certificate-based authentication are essential protections that testers can verify in practice.

Perhaps the most specialised area of all is the testing of medical IoT devices such as infusion pumps, smart monitors, and imaging equipment. These devices often run outdated firmware, use hardcoded credentials, or lack encryption altogether. Because they interface directly with patients and critical care, exploiting them can have life-threatening consequences. Ethical testers working in NHS or private healthcare settings must take a passive and risk-sensitive approach, simulating how a malicious actor could hijack communications or pivot through connected endpoints without endangering patient safety.

Ultimately, penetration testing is only valuable when it delivers actionable remediation guidance. A good healthcare penetration test report doesn’t just list findings — it provides clear, prioritised steps aligned with operational impact. For example, if a web vulnerability exposes patient appointment data but cannot be exploited without authenticated access, it may be deprioritised compared to an open RDP port with weak credentials on a critical care system.

Section 5: Choosing the Right Testing Partner

Healthcare systems require penetration testers who understand clinical workflows, compliance constraints, and operational sensitivity. Cybergen has extensive experience

working with NHS Trusts, private hospitals, and digital health startups to deliver:

• Safe, non-disruptive testing plans
• Support for DSP Toolkit submissions
• Threat intelligence aligned with NHS-specific risks
• Remediation workshops with technical and executive audiences

Learn more about our penetration testing for healthcare and how we tailor our approach to sensitive environments.

Summary: Proactive Security Saves More Than Just Data

The cost of a healthcare breach extends beyond data loss. It can disrupt care delivery, damage reputations, and erode public trust. With healthcare environments becoming more digital, connected, and remote, penetration testing is a proactive step toward resilience.

By regularly testing and securing systems that manage patient data, healthcare providers demonstrate both regulatory compliance and genuine commitment to patient safety.

If your organisation handles sensitive health data, now is the time to assess how secure it really is. Get in touch with Cybergen to discuss a healthcare penetration testing strategy that works for you.

Ready to strengthen your security posture? Contact us today for more information on protecting your business.