The law firm representing the luxury Trump International Hotel and Tower property in Las Vegas announced at data breach affecting its client. To comply with breach notification laws in many states, corporations (or their agents) typically submit breach notices (e.g., sample or final) to the attorney general or applicable legal agency in each state where there are affected residents.
The breach notice at the California Attorney General website (Adobe PDF) read, in part:
"... we are providing notice of a security incident possibly affecting certain individuals who made payment card purchases at Trump International Hotel & Tower Las Vegas, located at 2000 Fashion Show Drive, Las Vegas, NV... Although an independent forensic investigation has not conclusively determined that any particular customer’s payment card information was taken from the Hotel’s payment card system or misused as a result of the incident, we are providing this notice out of an abundance of caution to inform potentially affected customers of the incident... it appears that there may have been unauthorized malware access to payment card information as it was inputted into the payment card systems... including payment card account number, card expiration date, security code, and cardholder name) of individuals who used a payment card at the Hotel between May 19, 2014, and June 2, 2015, may have been affected..."
It seems that payment information was stolen by malware installed within infected terminals. The breach notice also mentioned that the hotel is working with law enforcement, banks, and an independent forensic investigation vendor. All, pretty standard stuff. The notice did not disclose the total number of records or consumers affected.
The breach notice includes instructions for affected customers to sign up for one year of free fraud resolution and identity protection services with Experian ProtectMyID. The offer is only for U.S. residents who used a payment card at the Hotel between May 19, 2014, and June 2, 2015. (Since the hotel's website includes content in several languages besides English, I guess that deep-pocketed customers from other countries are simply screwed.) That duration seems skimpy, since many other corporations have offered two years. The breach notice lists a hotel toll-free number for affected customers to get assistance and ask questions.
A check this morning of the hotel's home page did not find a link to a breach notice. Typically, a well-organized post-breach response also includes a website providing affecting customers with more information (or dedicated pages at their main site).
So, there seems to be two massive failures in this data breach. The first was a failure to promptly detect the unauthorized access. The second was a lengthy delay of more than a year to notify affected consumers. And, the investigation is still underway so things could be even worse.
Note: the Krebs On Security blog first broke news in July about data breaches at several hotels, including the Trump hotel in Las Vegas. One wonders why the hotel didn't announce the breach then.