The Compliance Clock is Ticking: Why Penetration Testing is No Longer Optional for Nonprofits

For many IT leaders in the education and non-profit sectors, cybersecurity can feel like a rapidly changing landscape of new threats and emerging best practices. However, beyond the tactical need to secure your data, there is a growing legal mandate: compliance. 

If your institution handles financial aid, processes credit card payments, or manages donor information, you are likely subject to strict federal and industry regulations that mandate regular security testing. At NYSERNet, we believe in moving from reactive to strategic; understanding these requirements is the first step in building a defensible security program. 

Higher Education and the GLBA Safeguards Rule 

Under the Gramm-Leach-Bliley Act (GLBA), many educational institutions are classified as "financial institutions" because they engage in activities financial in nature, such as processing student loans. The FTC Safeguards Rule provides concrete guidance on how these institutions must protect customer information. 

A critical element of this rule is the requirement to regularly monitor and test the effectiveness of your safeguards. Specifically, if your institution does not have a system for continuous monitoring the Rule mandates: 

• Annual Penetration Testing: A deep-dive assessment to circumvent or defeat security features. 
• Vulnerability Assessments: System-wide scans conducted at least every six months. 
• Reporting: You must report test results to your Board of Directors at least annually. 

NYSERNet’s penetration testing provides value beyond completing the test for compliance’s sake. Our proactive approach offers strategic recommendations and includes retesting after remediations are made. 

Museums, Theatres, and the PCI Standard 

If your organization processes, stores, or transmits cardholder data—whether for memberships, ticket sales, or donations—you must comply with the PCI Data Security Standard. 

The PCI ecosystem is designed to protect payment data throughout its entire lifecycle. To remain compliant, organizations must maintain a baseline of technical and operational requirements to protect their Cardholder Data Environment. NYSERNet’s penetration testing identifies exploitable weaknesses in these environments before they can be leveraged by attackers, ensuring your "digital front door" remains locked to adversaries. 

Cybersecurity Insurance 

Beyond legal and regulatory mandates, building a defensible security program requires addressing the evolving requirements of cybersecurity insurance. Modern insurance standards demand that institutions align their security strategies with specific business, legal, and contractual obligations. Simply having a policy is no longer enough; organizations must ensure their technical controls are robust enough to provide adequate coverage against today's sophisticated threats. Penetration tests are a standard measure of proof and are often required at regular intervals to maintain eligibility of coverage.  

In addition to comprehensive Penetration Testing, NYSERNet offers Cyber Insurance Review and Advisement to ensure your institution meets your specific insurance benchmarks. By proactively aligning your defenses with these standards, you can minimize potential disruptions and secure recovery efforts in the event of an attack.  

 The High Cost of Non-Compliance 

Ignoring these mandates carries risks that go far beyond a simple audit failure. The consequences of a breach are more severe than ever: 

• Financial Impact: In 2025, the average cost to recover from a ransomware attack in the higher education sector reached $0.90 million.
• Compromised Resiliency: 74% of successful ransomware attacks result in backup compromises, making recovery even more difficult and expensive. 
• Regulatory Action: The FTC enforces consumer protection laws and can take action against entities that fail to maintain required safeguards. 

Why NYSERNet? More Than Just a Scan 

Think of it this way: your organization’s compliance is like fire safety in a historic building. A vulnerability scan is like checking that the fire extinguishers are in their glass cases. A penetration test is like a fire marshal conducting a full-scale drill to ensure the alarms sound, the sprinklers activate, and every exit remains unblocked during a crisis. One confirms the tools are there; the other proves they work when a threat appears. 

Many organizations mistake a simple vulnerability scan for a true penetration test. While scans detect issues, NYSERNet’s Penetration Testing involves active exploitation by certified U.S.-based experts to assess actual risk. 

Aligned with the NIST 800-115 methodology and the "Detect" pillar of the NIST Cybersecurity Framework, our engagements are tailored to the unique needs of New York’s arts, research and education community. We don't just hand you a list of problems; we provide prioritized findings and built-in retesting to ensure your remediation efforts are effective. 

Building a secure, resilient organization is easier with a team at your back. You don't have to navigate these complexities alone—we’ve saved you a seat in our community. 

Ready to secure your compliance and your community? Contact us at membership@nysernet.org to develop your penetration testing plan today.