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Heartland Payment Systems Inc. said it was experiencing losses this quarter as a direct result of a massive data breach it disclosed in January when investigators discovered a malicious program sniffing credit card data passing through its systems. The company said it took a $2.5 million loss for the quarter as a result of spending more than $12.6 million in legal bills, fines from MasterCard and Visa and administrative costs. The announcement was made during the company's financial earnings call, where Carr said the costs associated with the breach could continue to climb. "Our defense of the claims regarding the processing system intrusion remains ongoing," he said. "Much of the legal work remains to be done and it is difficult to anticipate when these matters will come to a conclusion." Carr also admitted for the first time that since the Princeton, N.J.-based processing giant announced a breach of its systems, some of the payment processor's clients have switched to competitors as a result of the breach. He said some competing processors resorted to scare tactics. "We have had many competitors that have been very supportive and professional, and we certainly don't want to tar all of our competitors with the same brush," Carr said. "We have had some competitors telling merchants falsely that they would be fined $10,000 a day if they stay with Heartland. We think we're through the worst of that." Car said less than $1 million of the breach costs were fines levied by MasterCard and Visa against the company's sponsored banks. The fines are being contested, he said. More than $500,000 relates to a fine assessed by MasterCard against the sponsored banks in which the card company said Heartland failed to take appropriate action upon learning that a breach was suspected. Carr said the fine is in direct violation of both the MasterCard rules and law.

Rogue employees and hackers were the most commonly cited sources of data breaches reported during the first half of 2009, according to figures released this week by the Identity Theft Resource Center, a San Diego based nonprofit. The ID Theft Center found that of the roughly 250 data breaches publicly reported in the United States between Jan. 1 and Jun. 12, victims blamed the largest share of incidents on theft by employees (18.4 percent) and hacking (18 percent). Taken together, breaches attributed to these two types of malicious attacks have increased about 10 percent over the same period in 2008. Some 44 states and the District of Columbia now have laws requiring entities that experience a breach to publicly disclose that fact. Yet, few breached entities report having done anything to safeguard data in the event that it is lost or stolen. The ITRC found only a single breach in the first half of 2009 in which the victim reported that the lost or stolen data was protected by encryption technology. "It is a dual problem here undeterred by law or common sense," said ITRC co-founder Linda Foley. "You would think if all these organizations have to notify, that they would take some steps to make sure their data doesn't get exposed in the first place."

A New Jersey credit-card processor disclosed a data breach that analysts said may rank among the biggest ever reported. Heartland Payment Systems Inc. said Tuesday that cyber criminals compromised its computer network, gaining access to customer information associated with the 100 million card transactions it handles each month. The company said it couldn't estimate how many customer records may have been improperly accessed, but said the data compromised include the information on a card's magnetic strip -- card number, expiration date and some internal bank codes -- that could be used to duplicate a card. Heartland, of Princeton, N.J., processes transactions for more than 250,000 businesses nationwide, including restaurants and smaller retailers. Avivah Litan, an analyst at research company Gartner, called it the largest card-data breach ever, based on her conversations with industry executives. Previously, the largest known breach occurred when around 45 million card numbers were stolen from retail company TJX Cos. in 2005 and 2006. Robert Baldwin, Heartland's president and chief financial officer, said it was too early to say how many records were accessed and that calling it the largest-ever breach would be "speculative." Representatives of Visa Inc. and MasterCard Inc. alerted Heartland to a pattern of fraudulent transactions on accounts the processor handled sometime last fall, Mr. Baldwin said. But an internal investigation and audits failed to detect a security breach. Last week, however, a forensic investigator discovered evidence of the breach. Mr. Baldwin said Heartland was targeted with malicious software that was "light-years more sophisticated" than malevolent programs commonly downloaded from the Internet.

The California State Senate approved today SB 20, legislation by State Senator Joe Simitian (D-Palo Alto), which aims to strengthen existing privacy protection laws for California consumers. The new law builds on legislation authored by Simitian in 2002 that requires a business or government agency that incurs a data breach to provide notice to the individual(s) whose information was compromised. More than 40 states have adopted similar legislation since that time, largely based on the California measure. "No one likes to get the news that information about them has been stolen," said Simitian, "but when it happens, people are entitled to get a notice they can understand, and that helps them decide what to do next." "The premise is simple," added Simitian. "What you don´t know can hurt you. Ignorance is not bliss. And you can´t protect yourself if you don´t know you´re at risk." Simitian said his latest proposal (SB 20), "is designed to make a good law even better." California´s current security breach notification law (AB 700, Simitian -2002) requires notice to consumers when their information has been compromised, but does not require data holders to provide any standard set of information about the nature of the breach. SB 20 will enhance consumer knowledge about security breaches by requiring that the notification contain specified information, including the type of personal information breached and the date of the breach.

It's funny. Was it just a month ago that we were enjoying the holiday respite, wondering what 2009 would have in store for us? Mind you, I didn't have any delusions. After the breaches, news events and regulatory issues of 2008, I didn't think we were going to turn the calendar page and emerge in a new world of a healthy economy and soaring consumer confidence. But neither did I think, four weeks later, we'd already have our first major security breach of the year - Heartland Payment Systems (HPY) and that it would so dominate our industry's attention. I get it, though, why we're so enamored of this case. It speaks to our biggest fears, first of all, that unknown electronic assailants can sneak into our systems and pry away our customers' names and critical information. Then there's the unknown enormity - we truly don't know how big this breach was. And, finally, it hits home. For you, the banking institution, you're the one left replacing your customers' cards and explaining why. For me, the banking customer ... well, mine is one of the banks doing the explaining. Needless to say, we're monitoring accounts closely. So, we were among the first to break the Heartland story when it first broke last Tuesday, and we've continued to follow it closely. After the initial media surge, where we saw news outlets and solutions providers tripping over one another to opine over what they think happened to Heartland and what it all means, here is what I believe we've learned so far from the case: 1) The Damage Goes Far Beyond the Breach. Heartland execs absolutely did the right thing by stepping forward last week and saying "We were breached," but the company has suffered for it ever since. The market responded to the news by gutting the company's value from over $14 per share last Tuesday to a low of just under $8 this week. Reputationally, you just can't measure the damage - Heartland is now synonymous with "breach," and that's a tough tag to shake. Unable to answer quest

Visa Inc.'s top risk management executive today dismissed what she described as "recent rumblings" about the possible demise of the PCI data security rules as "premature" and "dangerous" to long-term efforts to ensure that credit and debit card data is secure. Speaking at Visa's Global Security Summit in Washington, Ellen Richey, the credit card company's chief enterprise risk officer, insisted that despite recent data breaches at two payment processors, the Payment Card Industry Data Security Standard (PCI DSS) "remains an effective security tool when implemented properly." Richey added that breaches such as the ones at Heartland Payment Systems Inc. and RBS WorldPay Inc. were shaping public opinion and obscuring what otherwise has been "substantial progress" on the security front over the past year. "I'm sure that everyone in this room has read the headlines questioning how an event of this magnitude could still happen today," Richey said, referring to the Heartland breach. "The fact is, it never should have" - and indeed wouldn't have if Heartland had been vigilant about maintaining its PCI compliance, according to Richey. "As we've said before," she continued, "no compromised entity has yet been found to be in compliance with PCI DSS at the time of a breach." Pointing to Visa's decision last week to remove both of the breached payment processors from its list of PCI-compliant service providers, Richey said that Heartland would face fines and probationary terms that were proportionate to the still-undisclosed magnitude of the breach. "While this situation is unfortunate, it does not make me question the tools we have at our disposal," she said of the PCI rules.

Heartland Payment Systems, the sixth-largest payments processor in the U.S., announced Monday that its processing systems were breached in 2008, exposing an undetermined number of consumers to potential fraud. Meanwhile, Forcht Bank, one of the 10 largest banks in Kentucky, told its customers it would begin reissuing 8,500 debit cards after being informed by its own card processor of a possible breach. In the case of Heartland, while the company continues to assess the damages inflicted by the attack, Robert Baldwin, the company's president and CFO, says law enforcement has already noted that the attack against his company is part of a wider cyber fraud operation. "The indication that it is tied to wider cyber fraud operation comes directly from conversations with the Department of Justice and the U.S. Secret Service," Baldwin says. The company says it believes the breach has been contained. Heartland, headquartered in Princeton, NJ, handles approximately 100 million transactions per month, although the number of unique cardholders is much lower. "It is still a question as to the percentage of the data flow they were able to get," Baldwin says, adding he would not speculate on the number of cards potentially exposed. Specifics surrounding when the breach occurred are still being analyzed. But Baldwin says two forensic auditing teams have been working on the breach analysis and investigation since late 2008, after Heartland received the notification from Visa and MasterCard. The investigation began immediately after the credit card companies told Heartland they saw suspicious activity surrounding processed card transactions. Described by Baldwin as "quite a sophisticated attack," he says it has been challenging to discover exactly how it happened.

Government Information Security Podcasts Credit Eligible As a GovInfoSecurity.com annual member, this content can be used toward your membership credits and transcript tracking. Click For More Info Heartland Breach -- What it Means to Banking Institutions: James Van Dyke, Javelin Strategy & Research January 29, 2009 The Heartland Payment Systems data breach - it's the first major security incident of 2009. But how big is it really? What are the key takeaways for banking institutions left explaining this breach to their customers? In an exclusive interview, James Van Dyke, Founder and President of Javelin Strategy & Research, discusses the implications of the Heartland case, offering insight on: Conclusions we can draw from the Heartland breach; How banking institutions should communicate with their customers; Vulnerabilities we should watch to avoid the next big breach. Van Dyke is founder and president of Javelin Strategy & Research. Javelin is the leading provider of independent, quantitative and qualitative research for payments, multi-channel financial services, security and fraud initiatives. Javelin's clients include the largest financial institutions, card issuers and technology vendors in the industry.

Senate Judiciary Chairman Patrick Leahy (D-Vt.) has reintroduced a data breach bill that would set tougher rules for government agencies and private sector firms regarding consumers' personal information. This will be the third time around the block for the Personal Data Privacy and Security Act, which has cleared the Judiciary Committee, but never come to a vote on the Senate floor. The bill would preempt the more than 40 state laws laying out requirements for notifying consumers in the event of a data breach, a long-deferred legislative goal that has the general support of the IT industry. But Leahy's bill is about more than just data breaches. Among other things, it would set baseline security information standards for government agencies, something that the Obama administration has begun to work on with the early steps of an overhaul of the government's cybersecurity apparatus. "This is a comprehensive bill that not only deals with the need to provide Americans with notice when they have been victims of a data breach, but that also deals with the underlying problem of lax security and lack of accountability to help prevent data breaches from occurring in the first place," Leahy said in a statement. "Passing this comprehensive data privacy legislation is one of my highest legislative priorities as Chairman of the Judiciary Committee."

Compared to other key corporate executives, CEOs appear to underestimate the IT security risks faced by their own organizations, according to a survey of C-level executives released today by the Ponemon Institute. The Ponemon survey (download PDF) of 213 CEOs, CIOs, COOs and other senior executives reveals what appears to be a perception gap between CEOs and other senior managers concerning information security issues. For instance, 48% of CEOs surveyed said they believe hackers rarely try to access corporate data. On the other hand, some 53% of other C-level executives believe that their company's data is under attack on a daily or even hourly basis. The survey also found that the top executives were less aware of specific security incidents at their companies than other C-level executives and are more confident that data breaches can be easily avoided. Ponemon found that CEOs tend to view data protection efforts as vital to maintaining good customer satisfaction levels and to the company's brand image. The other managers, however, were more likely to say that the most important role for data security efforts is to satisfy regulatory requirements. The survey also found that CEOs and other top managers differed in their opinion of who is responsible for protecting corporate data. While eight out of 10 respondents said they believe there is one person responsible for data protection in their organization, there was a sharp difference of opinion on just who that person was. More than half of the CEOs said that CIOs are responsible for protecting data at their companies; only 24% of other senior managers felt the same way. And 85% of respondents said someone else would be held responsible for a data breach. "On the issue of accountability, we found that while people acknowledged that data breaches were a problem, very few people felt that if [their company] suffered a breach, they would be held responsible," said Larry Ponemon, founder of the Ponemon Institute.

Compared to other key corporate executives, CEOs appear to underestimate the IT security risks faced by their own organizations, according to a survey of C-level executives released today by the Ponemon Institute. The Ponemon survey (download PDF) of 213 CEOs, CIOs, COOs and other senior executives reveals what appears to be a perception gap between CEOs and other senior managers concerning information security issues. For instance, 48% of CEOs surveyed said they believe hackers rarely try to access corporate data. On the other hand, some 53% of other C-level executives believe that their company's data is under attack on a daily or even hourly basis. The survey also found that the top executives were less aware of specific security incidents at their companies than other C-level executives and are more confident that data breaches can be easily avoided. Ponemon found that CEOs tend to view data protection efforts as vital to maintaining good customer satisfaction levels and to the company's brand image. The other managers, however, were more likely to say that the most important role for data security efforts is to satisfy regulatory requirements. The survey also found that CEOs and other top managers differed in their opinion of who is responsible for protecting corporate data. While eight out of 10 respondents said they believe there is one person responsible for data protection in their organization, there was a sharp difference of opinion on just who that person was. More than half of the CEOs said that CIOs are responsible for protecting data at their companies; only 24% of other senior managers felt the same way. And 85% of respondents said someone else would be held responsible for a data breach. "On the issue of accountability, we found that while people acknowledged that data breaches were a problem, very few people felt that if [their company] suffered a breach, they would be held responsible," said Larry Ponemon, founder of the Ponemon Institute.

Identity theft concerns are focused on the security and necessity of the collection process. Collecting personal information just because you can is unsafe. Organizations can reduce privacy risks by not collecting unnecessary personal info. Once the data gets into the data life cycle pipeline, the cost of managing and destroying it escalates. The Federal Trade Commission estimates that as many as 9 million people have their identities stolen every year. According to the Privacy Rights Clearinghouse, more than 200 million instances of data breaches have occurred since the beginning of 2005, and they show no signs of letting up. In the first quarter of 2008 alone, more than 85 million incidents were reported. The causes of data breaches run the gamut: Hackers get unencrypted, transmitted data and data at rest; laptops are stolen or lost; storage Relevant Products/Services devices are lost by third-party shipping companies; flash drives or PDAs are left lying around; Social Security numbers are accidentally printed on envelopes; or data is found on discarded computers. This article examines the organizational risks to CPAs and their clients or corporate employers of improperly managed data throughout the data life cycle. It also discusses best data management practices and proper procedures for responding to a data breach. Data breaches, whatever the cause, are costly. According to a study by the Ponemon Institute, the average cost of a data breach in 2007 was $6.3 million. The average cost to an organization per record compromised is about $197, which is typically spent on phone calls for customer notification, providing free credit monitoring, discounts on membership fees, or discounts on merchandise to make up for the security Relevant Products/Services breach. Some organizations also experience an increase in customer turnover. The organization typically spends additional money in data protection Relevant Products/Services enhancements. Companies sanctioned by

Point by Marcus Ranum THERE'S AN OLD SAYING, "Sometimes things have to get a lot worse before they can get better." If that's true, then breach notification laws offer the chance of eventual improvements in security, years hence. For now? They're a huge distraction that has more to do with butt-covering and paperwork than improving systems security. Somehow, the security world has managed to ignore the effect voluntary (?) notification and notification laws have had in other fields-namely, none.We regularly get bank disclosure statements, stock plan announcements, HIPAA disclosures, etc.-and they all go immediately in the wastebasket, unread.When I got my personal information breach notification from the Department of Veterans Affairs, it went in the trash too. Counterpoint by Bruce Schneier THERE ARE THREE REASONS for breach notification laws. One, it's common politeness that when you lose something of someone else's, you tell him. The prevailing corporate attitude before the law-"They won't notice, and if they do notice they won't know it's us, so we are better off keeping quiet about the whole thing"-is just wrong. Two, it provides statistics to security researchers as to how pervasive the problem really is. And three, it forces companies to improve their security. That last point needs a bit of explanation. The problem with companies protecting your data is that it isn't in their financial best interest to do so. That is, the companies are responsible for protecting your data, but bear none of the costs if your data is compromised. You suffer the harm, but you have no control-or even knowledge- of the company's security practices. The idea behind such laws, and how they were sold to legislators, is that they would increase the cost-both in bad publicity and the actual notification-of security breaches, motivating companies to spend more to prevent them. In economic terms, the law reduces the externalities and forces companies to deal with the true costs of

"This presentation contains statements of a forward-looking nature which represent our management's beliefs and assumptions concerning future events. Forward-looking statements involve risks, uncertainties and assumptions and are based on information currently available to us. Actual results may differ materially from those expressed in the forward-looking statements due to many factors, including without limitation, the impact that the significantly unfavorable economic conditions confronting the United States may have on our business, the results and effects the security breach of our processing system may have on us, including the costs and damages we may incur in connection with the claims arising from such breach that have been made and may in the future be made against us, the extent of cardholder information compromised and the possibility that such security breach could cause us to lose customers or make it difficult for us to obtain new customers, the possibility that we may not be successful in developing and implementing an end to end encryption solution, the possibility that if we are successful in developing and implementing an end to end encryption solution it may not prevent future security breaches of our payment processing system, and additional factors that are contained in the Company's Securities and Exchange Commission filings, including but not limited to, the Company's annual report on Form 10- K for the year ended December 31, 2008. We undertake no obligation to update any forward-looking statements to reflect events or circumstances that may arise after the date of this presentation. Topics / Agenda - The Future of Electronic Payments * What Is The Problem? The Cybercrimes Arms Race * Who Is Heartland Payment Systems? * What Happened and What Has/Will It Cost? * What Did We Do About It and What Are We Doing Now? * Massive Quantity/Quality of Breaches Call for Enhanced Solutions * Our New Solution Called E3 -

"Data broker ChoicePoint, the victim of a 2004 data breach affecting more than 160,000 U.S. residents, has agreed to strengthen its data security efforts and pay a fine for a second breach in 2008, the U.S. Federal Trade Commission said Monday. ChoicePoint, now a subsidiary of Reed Elsevier, will pay US$275,000 to resolve the newest FTC complaint. The FTC accused the company of failing to implement a comprehensive information security program to protect consumers' personal information, as required by the agency after the 2004 breach. The April 2008 breach compromised the personal data of 13,750 people, the FTC said in a press release. ChoicePoint turned off a "key" electronic security tool used to monitor access to one of its databases, and failed to detect that the security tool was turned off for four months, the FTC said. For a 30-day period, an unknown hacker conducted thousands of unauthorized searches of a ChoicePoint database containing sensitive consumer information, including Social Security numbers, the FTC said. After discovering the breach, the company notified the FTC. If the software tool had been working, ChoicePoint likely would have detected the intrusions "much earlier," the FTC said. "

"Consumers who have received a data breach notification letter are four times more likely than others to be the victim of identity theft, according to a survey released this week by Javelin Strategy and Research. Approximately 11 percent of U.S. consumers have received a data breach notification letter in the past 12 months with a third of the breaches involving Social Security numbers and 15 percent involving ATM PINs, according to Javelin's third annual survey of nearly 5,000 U.S. consumers, released Tuesday. Of those who have received a data breach notification letter in the past year, 19.5 percent said they were the victims of fraud associated with identity theft, compared to 4.3 percent who have not received a notification but were victimized. "It wasn't just a statistical anomaly," Robert Vamosi, a Javelin risk fraud and security analyst and the author of the study, told SCMagazineUS.com on Wednesday. "In 2007 and 2006, we saw a similar pattern, so this isn't a blip. This is something that has been going on for a while.""

The Heartland data breach is an opportunity for the US government to standardise data breach notification laws. Bill Conner, chairman, president and CEO of Entrust, claimed that following the revelation that more than 100 million credit cards could have been compromised, the government needs to continue to move quickly to standardise data breach notification laws and call for technology, such as encryption and stronger authentication, that truly protects consumer information. Conner said: "Cybercrime continues to grow and is increasingly affecting more and more of this country's citizens. To slow the upward trend of cybercrime in this country, all organisations - enterprise, consumer and even governments - need to carefully review current security approaches and identify key gaps within their infrastructures." He further called for Congress to pass a data breach notification law that better protects consumer identities through stronger data security standards with strong encryption. "This is an opportunity to do something about a security issue that impacts all Americans", said Conner.

Those who are superstitious may believe that bad things happen on Friday the 13th, but we will leave it to each individual and entity to formulate conclusions regarding the Health Information Technology for Economic and Clinical Health Act (the HITECH Act), which Congress passed late on Friday, February 13, 2009, and President Obama officially signed into effect on February 17, 2009. The HITECH Act addresses various aspects relating to the use of health information technology (H.I.T.), including providing for federal funding by way of grants and incentive payments in order to promote H.I.T. implementation. This Alert focuses, however, on Subtitle D of the HITECH Act, which includes important, new and far-reaching provisions concerning the privacy and security of health information that will materially and directly affect more entities, businesses and individuals in more diverse ways than ever before. These changes are further elaborated upon below, but this Alert can only highlight certain prominent issues under the HITECH Act and is by no means a comprehensive review of this lengthy and complex Act. For questions and additional guidance on the HITECH Act, contact your Fox Rothschild attorney or the authors of this Alert. New Privacy and Security Requirements * Security Breach Notification Requirements: Security breach notification requirements under the HITECH Act go into effect 30 days after the date that interim final regulations are promulgated, which will be no later than 180 days after the date of enactment of the HITECH Act (August 16, 2009). Covered entities, business associates and vendors who handle personal health records are required to abide by breach notification requirements. Violations of this requirement by vendors would be treated as an unfair and deceptive act or practice in violation of the Federal Trade Commission Act. If a breach affects more than 500 individuals of a particular state, notice also must be provided to prominent media outl

"Hackers are using a variety of weapons and exploiting errors such as default passwords and weak or misconfigured access control lists (ACLs), according to the latest Verizon Business Data Breach Investigations Report. The follow-up to April's 2009 Data Breach Investigation Report looks under the hood of the company's probes, analyzing how breaches happen and how to protect sensitive data. "Customers who read the 2009 Data Breach Investigation Report said they wanted to know how these attacks take place, give some examples from our caseloads and see if those circumstances can happen to them," said Wade Baker, Verizon Business research and intelligence principal. "

Last week, the government took another step toward closing a legal loophole in federal privacy and security rules for emerging Health 2.0 information technology applications by issuing proposed rules aimed at covering an estimated 900 companies and organizations offering personal health records and electronic systems connected to them. The Federal Trade Commission was careful to point out its new interim proposed rule on federal breach notification requirements for the developers of electronic PHR systems did not apply to covered organizations or their business associates as defined by the Health Insurance Portability and Accountability Act of 1996, heretofore the key federal privacy and security regulation. The FTC, operating under new authority given it by the American Recovery and Reinvestment Act of 2009, noted that its new rule seeks to cover previously unregulated entities that are part of a Health 2.0 product mix. FTC staff estimates that about 200 PHR vendors, another 500 related entities and 200 third-party service providers will be subject to the new breach notification rule. The staffers estimate that the 900 affected companies and organizations, on average, will experience 11 breaches each per year at a total cost of about $1 million per group, per year. Costs include investigating the breach, notifying consumers and establishing toll-free numbers for explaining the breaches and providing additional information to consumers. Pam Dixon, founder and executive director of the World Privacy Forum, said that this isn't the first involvement of the FTC in healthcare-related regulation, noting the consumer protection agency joined with the Food and Drug Administration in a joint statement on the marketing of direct-to-consumer genetic tests. The FTC also has worked in the field of healthcare competition. She noted the compliance deadline with the FTC's "red flag rules" on provider organizations that provide consumer credit to patients for installment payment

Individuals have been at risk of having their personal information stolen and used to commit identity-related crimes long before the emergence of the Internet. What the Information Age has changed, however, is the method by which identity thieves can access and exploit the personal information of others. One method in particular leaves hundreds of thousands, and in some cases tens of millions, of individuals at risk for identity theft: large scale data breaches by skilled hackers. In this method, criminals remotely access the computer systems of government agencies, universities, merchants, financial institutions, credit card companies, and data processors, and steal large volumes of personal information on individuals. Such large scale data breaches have revolutionized the identity theft landscape as it relates to fraud on existing accounts through the use of compromised credit and debit card account information. Large scale data breaches would be of no more concern than small scale identity thefts if criminals were unable to quickly and widely distribute the stolen information for subsequent fraudulent use (assuming, of course, that the breach would be quickly detected). Such wide-scale global distribution of stolen information has been made possible for criminals with the advent of criminal websites, known as "carding forums," dedicated to the sale of stolen personal and financial information. These websites allow criminals to quickly sell the fruits of their ill-gotten gains to thousands of eager fraudsters

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