182 posts categorized "Breach Notification" Feed

Evite Admitted Data Breach. Doesn't Disclose The Number Of Users Affected

Evite logo Evite, the online social and invitations site, disclosed last month a data breach affecting some of its users:

"We became aware of a data security incident involving potential unauthorized access to our systems in April 2019. We engaged one of the leading data security firms and launched a thorough investigation. The investigation potentially traced the incident to malicious activity starting on February 22, 2019. On May 14, 2019, we concluded that an unauthorized party had acquired an inactive data storage file associated with our user accounts... Upon discovering the incident, we took steps to understand the nature and scope of the issue, and brought in external forensic consultants that specialize in cyber-attacks. We coordinated with law enforcement regarding the incident, and are working with leading security experts to address any vulnerabilities..."

Evite was founded in 1998, so there could be plenty of users affected. The breach announcement did not disclose the number of users affected.

The Evite breach announcement also said, "No user information more recent than 2013 was contained in the file" which was accessed/stolen by unauthorized persons. Evite said it has notified affected users, and has reset the passwords of affected users. The Evite system will prompt affected users to create new passwords when signing into the service.

The announcement listed the data elements accessed/stolen: names, usernames, email addresses, and passwords. If users also entered their birth dates, phone numbers, and mailing addresses then those data elements were also access/stolen. Social Security numbers were not affected since Evite doesn't collect this data. Evite said payment information (e.g., credit cards, debit cards, bank accounts, etc.) was not affected because:

"We do not store financial or payment information. If you opted to store your payment card in your account, your payment information is maintained by and stored on the internal systems of our third-party vendor."

Thank goodness for small wonders. The Evite disclosure did not explain why passwords were not encrypted, nor if that or other data elements would be encrypted in the future. As with any data breach, context matters. ZD Net reported:

"... a hacker named Gnosticplayers put up for sale the customer data of six companies, including Evite. The hacker claimed to be selling ten million Evite user records that included full names, email addresses, IP addresses, and cleartext passwords. ZDNet reached out to notify Evite of the hack and that its data was being sold on the dark web on April 15; however, the company never returned our request for comment... Back in April, the data of 10 million Evite users was put up for sale on a dark web marketplace for ฿0.2419 (~$1,900). The same hacker has breached, stolen, and put up for sale the details of over one billion users from many other companies, including other major online services, such as Canva, 500px, UnderArmor, ShareThis, GfyCat, Ge.tt, and others."

The incident is another reminder of the high value of consumers' personal data, and that hackers take action quickly to use or sell stolen data.


Several States Strengthened Their Data Breach Notification Laws in 2019

Legislatures in several states are improving their existing data breach notification laws to provide stronger protections for consumers.

To fully appreciate the changes requires an understanding of the current legal status. The National Conference of State Legislatures summarized the current status:

"All 50 states, the District of Columbia, Guam, Puerto Rico and the Virgin Islands have enacted legislation requiring private or governmental entities to notify individuals of security breaches of information involving personally identifiable information. Security breach laws typically have provisions regarding who must comply with the law (e.g., businesses, data/information brokers, government entities, etc.); definitions of “personal information” (e.g., name combined with SSN, drivers license or state ID, account numbers, etc.); what constitutes a breach (e.g., unauthorized acquisition of data); requirements for notice (e.g., timing or method of notice, who must be notified); and exemptions (e.g., for encrypted information)."

The increased legislative activity comes in the aftermath of the massive Equifax breach in 2017 affecting 145.5 million persons. 2018 was a terrible year with more than one billion consumer accounts affected by multiple data breaches.

Many of the improvements across states requires sooner notice to affected persons, so consumers can check their bank/card statements for fraudulent activity, and take other security actions. Without sooner notice, fraud can perpetuate with more money stolen.

Now, the legislative activity in selected states.

First, legislators amended the requirements in the Maryland Personal Information Protection Act (MPIPA), or House Bill 1154. Maryland Governor Larry Hogan approved of the changes, which will go into effect on October 1, 2019. A summary of the changes:

  • Requires businesses that own or license "computerized data that includes personal information of an individual residing in the State" to conduct a good-faith breach investigation to determine data abuse when they discover or are notified of a data breach,
  • Requires notification of affected persons within 45 days, and
  • Requires businesses to maintain records of the breach for three years of its breach investigation and determination that notification of affected persons is not required.

Second, Massachusetts Governor Charlie Baker signed legislation in January which went into effect on April 11, 2019. Changes in the new law: no fees for consumers to place, lift, or remove Security Freezes; credit monitoring required when Social Security numbers disclosed during the breach; and an expanded list of requirements when businesses provide notice to the Massachusetts Attorney General and to the Massachusetts Office of Consumer Affairs and Business Regulation (OCABR).

Third, New Jersey amended its breach law. SC Magazine summarized the changes:

"The new law expands the definition of what constitutes personal information that, if exposed in a breach, would require a company to issue a notification. Once S-52 takes effect on Sept. 1, 2019, personal information will also include a “user name, email address, or any other account holder identifying information, in combination with any password or security questions and answer…” the law states."

Fourth, Oregon Governor Kate Brown signed into law Senate Bill 684 on May 24, 2019. The JD Supra site reported:

"The most significant changes are around service providers, who will take on an independent obligation to notify the state Attorney General (AG) about data security breaches. A handful of other, more subtle changes are also included in the amendments, which take effect January 1, 2020... The obligation that service providers notify the AG is triggered by breaches affecting the personal information of over 250 Oregon consumers, or when the number cannot be determined... The new obligation increases the number of parties involved in incident response and notice decisions... This round of amendments adds user names, combined with password or other means of authentication, to the list of notice-triggering personal information... One other amendment also touches service providers. Where previously service providers had to notify business customers “as soon as practicable” after discovering a breach, the amendments set a deadline of 10 days."

Many companies outsource back-office work to vendors. So, the Oregon law keeps pace with common business practices. Readers wanting to learn more can read this blog's Outsourcing section.

A new, separate bill in Oregon covers internet-connected devices, also called the Internet of Things (IoT). Many consumers have installed IoT devices in their homes. According to JD Supra:

"The Oregon connected device security law is largely consistent with California’s new connected device security law, and both take effect January 1, 2020. Both require that manufacturers equip IoT devices with reasonable security features. Under either statute that can mean setting unique passwords for each unit shipped, or requiring end users to set a new password when they first access the device, in order to access the devices remotely from outside the devices’ local area network. This is a floor, not a ceiling, and both laws leave room for other security features..."

When manufacturers sell IoT devices all configured with the same universal password, it is a huge security problem. Bad actors can remotely access consumers' IoT devices to commit identity theft, fraud, and more. Consumers require greater protection, and the new IoT law is a good first step. Readers wanting to learn more can read this blog's Internet of Things section.

Fifth, Washington Governor Jay Inslee signed signed HB 1071 on May 7) which expanded the state’s data breach notification law. The changes become effective March 1, 2020. The National Law Review reported that breach:

"... notices must be provided no more than thirty days after the organization discovers the breach. This applies to notices sent to affected consumers as well as to the state’s Attorney General. The threshold requirement for notice to the Attorney General remains the same—it is only required if 500 or more Washington residents were affected by the breach."

The new law in Washington also expanded the list of sensitive data elements comprising "personal information" when combined with a person's name: birth date; "unique private key used to authenticate" electronic records; passport, military, and student ID numbers; health insurance policy or identification number; medical history, health conditions, diagnoses, and treatments; and biometric data (e.g., fingerprints, retina scans, voiceprints, etc.).

As more states announce amended breach notification laws, this blog will cover those actions.


CBP Breach Disclosed Images Of Travelers' Faces And Vehicle License Plates. Many Unanswered Questions

United States Customs and Border Patrol logo A security breach at a vendor used by U.S. Customs & Border Patrol (CBP) has disclosed the images of both travelers and vehicles license plates. The Washington Post reported:

"Customs officials said in a statement Monday that the images, which included photos of people’s faces and license plates, had been compromised as part of an attack on a federal subcontractor. CBP makes extensive use of cameras and video recordings at airports and land border crossings, where images of vehicles are captured. Those images are used as part of a growing agency facial-recognition program designed to track the identity of people entering and exiting the United States. Fewer than 100,000 people were impacted, said CBP... Officials said the stolen information did not include other identifying information, and no passport or other travel document photos were compromised..."

Reportedly, CBP learned about the breach on May 31. The newspaper also reported:

"CBP said copies of “license plate images and traveler images collected by CBP” had been transferred to the subcontractor’s company network, violating the agency’s security and privacy rules. The subcontractor’s network was then attacked and breached. No CBP systems were compromised, the agency said."

A reporter posted on Twitter the brief statement by CBP, which was sent to selected news organizations:

"On May 31, 2009, CBP learned that a subcontractor, in violation of CBP policies and without CBP's authorization or knowledge, had transferred copies of license plate images and traveler images collected by CBP to the subcontractor's company network. The subcontractor's network was subsequently compromised by a malicious cyber-attack. No CBP systems were compromised.

Initial information indicates that the subcontractor violated mandatory security and privacy controls outlined in their contract. As of today, none of the image data has been identified on the Dark Web or internet. CBP has alerted Members of Congress and is working closely with other law enforcement agencies and cybersecurity entities, and its own Office of Professional Responsibility to actively investigate the incident. CBP will unwaveringly work with all partners to determine the extent of the breach and the appropriate response. CBP has removed from service all equipment related to the breach and is closely monitoring all CBP work by the contractor..."

Well, that brief statement is a start... a small start. This security breach is very troubling for several reasons.

First, it seems that CBP was unaware of the contractual violation (e.g., downloaded images) until it was informed of the data breach. That suggests an inadequate contractual agreement between the vendor and CBP; or failures by CBP to monitor and enforce its contracts. That also raises more questions:

  • When and which executives at the vendor will be reprimanded for this violation?
  • Why did CBP fail to identify the download violation?
  • What changes are underway to prevent future violations?
  • Why is CBP continuing to use a vendor known to have severely violated its contractual agreement?
  • What other vendors have violated CBP contracts?

Second, CBP refused to disclose the name of the vendor. Why? What would this accomplish? Its statement described the breach as a "malicious cyberattack." That seems to warrant disclosure. Were CBP executives caught unprepared?

Thankfully, reporters at the Washington Post continued investigating:

"... a Microsoft Word document of CBP’s public statement, sent Monday to Washington Post reporters, included the name “Perceptics” in the title: “CBP Perceptics Public Statement.” Perceptics representatives did not immediately respond to requests for comment... reporters at The Register, a British technology news site, reported late last month that a large haul of breached data from the firm Perceptics was being offered as a free download on the dark web."

So, we don't know for sure if Perceptics was the CBP vendor. However, the May 23rd article in The Register indicates that Perceptics executives were already aware of the breach. CBP executives should have known about the breach on May 23, too, since the article mentioned both entities. Then, why did the CBP statement say it learned of the breach on May 31st? Something here smells -- arrogance, incompetence, or both.

Third, a check at press time of the CBP website and newsroom failed to find any mentions of the security breach. CBP executives have had since May 31st (or since May 23rd), so why send a statement only to select news organizations? Why not publish that statement on its website, too? Were CBP executives caught unprepared and then rushed a haphazard response? When will the breach investigation report be released?

This is troubling. It suggests either arrogance or unpreparedness. As a taxpayer, my money funds CBP activities. I want to know that my money is being spent effectively.

Fourth, the lack of a detailed breach announcement means many related questions remain unanswered:

  • When will CBP notify affected persons? If the vendor will notify affected persons, then CBP must disclose the vendor's name in advance.
  • What assistance (e.g., free credit monitoring) will CBP provide affected persons?
  • What is the status of the post-breach investigation? It helps to know how attackers broke in so effective fixes can be implemented.
  • What other data elements were accessed/stolen? Metadata (e.g., image date and timestamp, border crossing GPS location, entering or exiting USA, vehicle brand and model, number and ages of any passengers in vehicles, etc.) attached to the images can be just as damaging.
  • Were any data elements encrypted? If not, why not?
  • Can facial images be matched to vehicle plate images, and/or to other data elements? If so, this creates more problems for impacted persons.
  • When will fixes be implemented so this doesn't happen again?
  • Exactly how many persons were affected, and in what states? Local states' breach notification laws may apply.
  • How many of the affected persons are U.S. citizens? If the 100,000 estimate applies to only affected U.S. citizens, then we need to know the true total number of persons impacted by the breach.
  • Does the 100,000 estimate refer to facial images only? If so, then exactly how many vehicle license plate images were disclosed?

The statement of "fewer than 100,000 persons impacted" seems vague. A breach investigation should determine two fairly precise items: the number of facial images accessed/stolen, and the number of license plate images accessed/stolen.

Plus, it seems wise to assume more data was stolen during the breach. Why? Consider this report by The Atlantic:

"I would be cautious about assuming this data breach contains only photo data," said Chad Loder, the CEO of Habitu8, a cybersecurity firm that trains other companies on security awareness. The full scope of the breach may be much larger than what CBP revealed in its original statement, he said. In recent years, CBP has asked travelers for fingerprints, facial data, and, recently, even social-media accounts. "If CBP’s contractor was targeted specifically, it’s unlikely that the attacker would have stopped with just photo data..."

If social media passwords were stolen, then affected persons need to know so they can change online passwords. And, elected officials are also asking questions. The Hill reported:

"House Homeland Security Committee Chairman Bennie Thompson (D-Miss.) announced on Monday that his committee would hold hearings next month to examine the collection of biometric information by the Department of Homeland Security (DHS), which includes CBP... Homeland Security Committee ranking member Mike Rogers (R-Ala.), used the breach to criticize DHS’s handling of cybersecurity challenges, saying in a statement to The Hill that "the agency is ill-equipped to handle emerging cyberthreats"... Representative Cedric Richmond (D-La.), the chairman of the House Homeland Security subcommittee on cybersecurity, also called for more answers about the breach, which he said would inform Congress's next steps... Senator Brian Schatz (D-Hawaii), the ranking member of the Senate Commerce Subcommittee on Communications, Technology, Innovation and the Internet, said he thinks the breach merits an investigation by the Office of the Inspector General."

Good suggestion by Senator Schatz. Clearly, there's plenty more news to come. Plenty.


Two Data Breaches At Collections Vendor Used By Healthcare Testing Firms Affect About 19 Million Persons

Two healthcare data breaches have affected about 19 million persons, so far.

First, a data breach at a third-party collections firm has affected about 11.9 million patients at Quest Diagnostics, a medical testing firm. Quest announced in a June 3rd news release that American Medical Collection Agency (AMCA) notified it of data breach affecting Quest patients:

"... an unauthorized user had access to AMCA’s system...AMCA provides billing collections services to Optum360, which in turn is a Quest contractor. Quest and Optum360 are working with forensic experts to investigate the matter. AMCA first notified Quest and Optum360 on May 14, 2019 of potential unauthorized activity on AMCA’s web payment page. On May 31, 2019, AMCA notified Quest and Optum360 that the data on AMCA’s affected system included information regarding approximately 11.9 million Quest patients. AMCA believes this information includes personal information, including certain financial data, Social Security numbers, and medical information, but not laboratory test results."

Quest said that AMCA hasn't yet provided it with details about the data breach. The news release did not state when AMCA or Quest would directly notify affected patients. Hopefully, future news releases will provide dates when the breach occurred, how the attackers broke in, and the fixes underway so this doesn't happen again.

Second, a data breach at the same third-party collections firm has also affected about 7.7 million customers of LabCorp, another medical testing firm. LabCorp disclosed in a filing with the U.S. Securities and Exchange Commission that AMCA notified it of data breach which occurred between August 1, 2018 and March 30, 2019. The filing did not state the date when AMCA notified LabCorp. The filing did state:

"AMCA is an external collection agency used by LabCorp and other healthcare companies. LabCorp has referred approximately 7.7 million consumers to AMCA... AMCA’s affected system included information provided by LabCorp. That information could include first and last name, date of birth, address, phone, date of service, provider, and balance information. AMCA’s affected system also included credit card or bank account information that was provided by the consumer to AMCA... AMCA has advised LabCorp that Social Security Numbers and insurance identification information are not stored or maintained for LabCorp consumers."

LabCorp said in the filing that it didn't provide patients' ordered tests, laboratory results, or diagnostic information to AMCA. AMCA is currently notifying about 200,000 LabCorp consumers whose credit card or bank account information may have been accessed. Also:

"AMCA has not yet provided LabCorp a list of the affected LabCorp consumers or more specific information about them. AMCA has indicated that it is continuing to investigate this incident and has taken steps to increase the security of its systems, processes, and data. LabCorp takes data security very seriously, including the security of data handled by vendors. AMCA has informed LabCorp that it intends to provide the approximately 200,000 affected LabCorp consumers with more specific information about the AMCA Incident, in addition to offering them identity protection and credit monitoring services for 24 months."

Given the ongoing investigation and breach notification, more news seems likely. Both breaches suggest other AMCA clients may have been affected. A check of the AMCA website at press time failed to find any news releases or mentions of both data breaches. C/Net reported:

"LabCorp also said that as a result of the breach, it's stopped sending new collection requests to the AMCA and suspended the AMCA's work on any pending requests related to LabCorp customers... LabCorp declined to comment beyond its SEC filing. AMCA said it conducted an internal audit after being notified of the breach by an outside security compliance firm and took down its web payments page. The company has also hired a third-party forensics firm to investigate the breach and has notified law enforcement."

The Krebs On Security blog reported:

"... AMCA also does business under the name “Retrieval-Masters Credit Bureau,” a company that has been in business since 1977. Retrieval-Masters also has an atrocious reputation for allegedly harassing consumers for debts they never owed. A search on the company’s name at the complaints page of the Consumer Financial Protection Bureau (CFPB) turns up almost 700 complaints for Retrieval-Masters. The company has an abysmal “F” rating from the Better Business Bureau, with 60 complaints closed against it in the last three years. Reviewing a number of those complaints reveals some of the AMCA’s other current and/or previous clients, including New Jersey’s EZPass system.

Both data breaches reminder patients that when companies outsource collections activities, patients' sensitive healthcare and payment information are often shared with outsource vendors. The lack of breach details makes one wonder if AMCA executives were caught unprepared with both inadequate data security on its payments website, and post-breach responses. Hopefully, future news reports will clarify things.


California Seeks To Close Loopholes In Its Data Breach Notification Law

California pursues legislation to close loopholes in its existing data breach notification law. Current state law in California does not require businesses to notify consumers when their passport and biometric data is exposed or stolen during a data breach. The proposed law would close that loophole.

The legislation was prompted by the gigantic data breach at Marriott's Starwood Hotels unit. The sensitive information of more than 327 million guests was accessed by unauthorized persons. The data accessed -- and probably stolen -- included guests' names, addresses, at least 25 million passport numbers, and more. California Attorney General Xavier Becerra announced the proposed legislation:

"Though [Marriott] did notify consumers of the breach, current law does not require companies to report breaches if only consumers’ passport numbers have been improperly accessed... In 2003, California became the first state to pass a data breach notification law requiring companies to disclose breaches of personal information to California consumers whose personal information was, or was reasonably believed to have been, acquired by an unauthorized person... This bill would update that law to include passport numbers as personal information protected under the statute. Passport numbers are unique, government-issued, static identifiers of a person, which makes them valuable to criminals seeking to create or build fake profiles and commit sophisticated identity theft and fraud. AB 1130 would also update the statute to include protection for a person’s unique biometric information, such as a fingerprint, or image of a retina or iris."

Assembly member Marc Levine (D-San Rafael) introduced the proposed legislation to the California House, and said in a statement:

“There is a real danger when our personal information is not protected by those we trust... Businesses must do more to protect personal data, and I am proud to stand with Attorney General Becerra in demanding greater disclosure by a company when a data breach has occurred. AB 1130 will increase our efforts to protect consumers from fraud and affirms our commitment to demand the strongest consumer protections in the nation."

Good. There are too many examples of companies failing to announce data breaches affecting companies. TechCrunch reported that AB 1130:

"... comes less than a year after state lawmakers passed the California Privacy Act into law, greatly expanding privacy rights for consumers — similar to provisions provided to Europeans under the newly instituted General Data Protection Regulation. The state privacy law, passed in June and set to go into effect in 2020, was met with hostility by tech companies headquartered in the state... Several other states, like Alabama, Florida and Oregon, already require data breach notifications in the event of passport number breaches, and also biometric data in the case of Iowa and Nebraska, among others..."

Kudos to California for moving to better protect consumers. Hopefully, other states will also update their breach notification laws.


Marriott Lowered The Number Of Guests Affected By Its Data Breach. Class Action Lawsuits Filed

Marriott International logo Important updates about the gigantic Marriott-Starwood data breach. The incident received more attention after security experts said that China's intelligence agencies may have been behind the cyberattack, which also targeted healthcare insurance companies.

Earlier this month, Marriott announced a lower number of guests affected:

"Working closely with its internal and external forensics and analytics investigation team, Marriott determined that the total number of guest records involved in this incident is less than the initial disclosure... Marriott now believes that the number of potentially involved guests is lower than the 500 million the company had originally estimated [in November, 2018]. Marriott has identified approximately 383 million records as the upper limit for the total number of guest records that were involved...

The announcement also said that fewer than 383 million different persons were affected because its database contained multiple records for the same guests. The announcement also stated that about:

"... 5.25 million unencrypted passport numbers were included in the information accessed by an unauthorized third party. The information accessed also includes approximately 20.3 million encrypted passport numbers... Marriott now believes that approximately 8.6 million encrypted payment cards were involved in the incident. Of that number, approximately 354,000 payment cards were unexpired as of September 2018..."

This is mixed news. Fewer breach victims is good news. The bad news: multiple database records for the same guests, and unencrypted passport numbers. Better, stronger data security always includes encrypting sensitive information. The announcement did not explain why some data was encrypted and some wasn't.

The hotel chain said that it will terminate its Starwood reservations database at the end of the year, and continue its post-breach investigation:

"While the payment card field in the data involved was encrypted, Marriott is undertaking additional analysis to see if payment card data was inadvertently entered into other fields and was therefore not encrypted. Marriott believes that there may be a small number (fewer than 2,000) of 15-digit and 16-digit numbers in other fields in the data involved that might be unencrypted payment card numbers. The company is continuing to analyze these numbers to better understand if they are payment card numbers and, if they are payment card numbers, the process it will put in place to assist guests."

Also, the hotel chain admitted during its January 4th announcement that it still wasn't fully ready to help affected guests:

"Marriott is putting in place a mechanism to enable its designated call center representatives to refer guests to the appropriate resources to enable a look up of individual passport numbers to see if they were included in this set of unencrypted passport numbers. Marriott will update its designated website for this incident (https://info.starwoodhotels.com) when it has this capability in place."

In related news, about 150 former guests have sued Marriott. Vox reported that a class-action lawsuit:

"... was filed Maryland federal district court on January 9, claims that Marriott did not adequately protect guest information before the breach and, once the breach had been discovered, “failed to provide timely, accurate, and adequate notice” to guests whose information may have been obtained by hackers... According to the suit, Marriott’s purchase of the Starwood properties is part of the problem. “This breach had been going on since 2014. In conducting due diligence to acquire Starwood, Marriott should have gone through and done an accounting of the cybersecurity of Starwood,” Amy Keller, an attorney at DiCello Levitt & Casey who is representing the Marriott guests, told Vox... According to a December report by the Wall Street Journal, Marriott could have caught the breach years earlier."

At least one other class-action lawsuit has been filed by breach victims.


Massive Data Breach At Quora Affects 100 Million Users

Quora logo Quora, the knowledge-sharing social networking site, announced on Monday a data breach affecting about 100 million of its users. The company discovered the breach on Friday, and a breach investigation is ongoing.

The company’s Chief Executive Officer, Adam D’Angelo, wrote in a blog post that the following data elements were compromised or stolen:

"a) Account information, e.g. name, email address, encrypted password (hashed using bcrypt with a salt that varies for each user), data imported from linked networks when authorized by users; b) Public content and actions, e.g. questions, answers, comments, upvotes; and c) Non-public content and actions, e.g. answer requests, downvotes, direct messages (note that a low percentage of Quora users have sent or received such messages)"

Quora has cancelled affected users' passwords. Quora does not yet know exactly how unauthorized persons accessed its system. The breach announcement did not state when the intrusion began. D'Angelo added:

"We're still investigating the precise causes and in addition to the work being conducted by our internal security teams, we have retained a leading digital forensics and security firm to assist us. We have also notified law enforcement officials."

Affected users are being notified via email. Affected users returning to the site must reset their accounts with new passwords. Quora encourages users with questions to visit its breach help site. Users are warned to change their online passwords.

The New York Times reported:

"... the incident was unlikely to result in identity theft, as the site does not collect sensitive information such as credit card or Social Security numbers... 300 million people around the world use its site at least once a month to ask and answer questions about politics, faith, calculus, unrequited love, the meaning of life and more. By comparison, Twitter claims 326 million monthly active users. But since it blasted onto the social media landscape in 2010, igniting a blaze of interest among tech company employees, Quora has not become the mainstream cultural force that Twitter has..."

This breach is another reminder to all consumers to never use the same password at multiple sites. Cybercriminals are persistent, and will reuse stolen passwords to see which other sites they can break into to steal sensitive personal and payment information.

If you received an email breach notice from Quora, please share it below (after deleting any sensitive personal data).


Gigantic Data Breach At Marriott International Affects 500 Million Customers. Plenty Of Questions Remain

Marriott International logo A gigantic data breach at Marriott International affects about 500 million customers who have stayed at its Starwood network of hotels in the United States, Canada, and the United Kingdom. Marriott International announced the data breach on Friday, November 30th, and set up a website for affected Starwood guests.

According to its breach announcement, an "internal security tool" discovered the breach on September 8, 2018. The initial data breach investigation determined that unauthorized persons accessed its registration database as far back as 2014, and had both copied and encrypted information before removing it. Marriott engaged security experts, the information was partially decrypted on November 19, 2018, and the global hotel chain determined that the information was from its Starwood guest reservation database.

Starwood Preferred Guest logo The Starwood hotels network includes brands such as W Hotels, St. Regis, Sheraton Hotels & Resorts, Westin Hotels & Resorts, Le Méridien Hotels & Resorts, Four Points by Sheraton, and more. Marriott has not finished decrypting all information, so there may be future updates from the breach investigation.

For 327 million guests, the personal data items stolen included a combination of name, mailing address, phone number, email address, passport number, Starwood Preferred Guest (“SPG”) account information, date of birth, gender, arrival and departure information, reservation date, and communication preferences. For some guests, the information stolen also included payment card numbers and payment card expiration dates. While Marriott said the payment card numbers were encrypted using Advanced Encryption Standard encryption (AES-128), its warned that it doesn't yet know if the encryption keys (needed to decrypt payment information) were also stolen.

For 173 million guests, fewer personal data items were stolen included, "name and sometimes other data such as mailing address, email address, or other information." Marriott International said its Marriott-branded hotels were not affected since they use a different reservations database on a different server.

Marriott said it has notified law enforcement, is working with law enforcement, and has begun to notify affected guests via email. The hotel chain will offer affected guests in select countries one year of free enrollment in the WebWatcher program which, "monitors internet sites where personal information is shared and  an alert to the consumer if evidence of the consumer’s personal information is found." WebWatcher will not be offered to all affected guests. Eligible guests should read the fine print, which the Starwood breach site summarized:

"Due to regulatory and other reasons, WebWatcher or similar products are not available in all countries. For residents of the United States, enrolling in WebWatcher also provides you with two additional benefits: (1) a Fraud Loss Reimbursement benefit, which reimburses you for out-of-pocket expenses totaling up to $1 million in covered legal costs and expenses for any one stolen identity event. All coverage is subject to the conditions and exclusions in the policy; and (2) unlimited access to consultation with a Kroll fraud specialist. Consultation support includes showing you the most effective ways to protect your identity, explaining your rights and protections under the law, assistance with fraud alerts, and interpreting how personal information is accessed and used..."

The seriousness of this data breach cannot be overstated. First, it went undetected for a very long time. Marriott needs to explain that and the changes it will implement with an improved "internal security tool" so this doesn't happen again. Second, 500 million is an awful lot of affected customers. An awful lot. Third, breach CNN Business reported:

"Because the hack involves customers in the European Union and the United Kingdom, the company might be in violation of the recently enacted General Data Protection Regulation (GDPR). Mark Thompson, the global lead for consulting company KPMG's Privacy Advisory Practice, told CNN Business that hefty GDPR penalties will potentially be slapped on the company. "The size and scale of this thing is huge," he said, adding that it's going to take several months for (EU) regulators to investigate the breach."

Fourth, the data items stolen are sufficient to cause plenty of damage. Security experts advise affected customers to change their Starwood passwords, check the answers.Kroll.com breach site next week to see if their information was compromised/stolen, sign up for credit monitoring (if they don't already have it), watch their payment or bank accounts for fraudulent entries, and consider an early renewal if your passport number was compromised/stolen. Fifth, companies usually arrange free credit monitoring for breach victims for one or two years. So far, Marriott hasn't done this. Maybe it will. If not, Marriott needs to explain why.

Sixth, breach notification of affected guests via email seems sketchy... like Marriott is trying to cut corners and costs. History is littered with numerous examples of skilled spammers and cybercriminals using faked or spoofed email to trick consumers into revealing sensitive personal and payment information. It will be interesting to see how Marriott's breach notification via email works and manages this threat.

Seventh, lawsuits and other investigations have already begun. ZDNet reported:

"... two Oregon men sued international hotel chain Marriott for exposing their data. Their lawsuit was followed hours later by another one filed in the state of Maryland. Both lawsuits seek class-action status. While plaintiffs in the Maryland lawsuit didn't specify the amount of damages they were seeking from Marriott, the plaintiffs in the Oregon lawsuit want $12.5 billion in costs and losses. his should equate to $25 for each of the 500 million users who had their personal data stolen from Marriott's serv ers... The Maryland lawsuit was filed by Baltimore law firm Murphy, Falcon & Murphy..."

Bloomberg BNA announced:

"The Massachusetts, New York and Illinois state attorneys general quickly announced they would examine the hack. Connecticut George Jepsen (D) is also looking into the matter, a spokesman told Bloomberg Law."

Eighth, the breach site's website address unnecessarily vague: answers.kroll.com. Frankly, a website address like "starwood-breach.kroll.com" or "marriott-breach.kroll.com" would have been better. (The combination of email notification and vague website name seems eerily similar to the post-breach clusterf--k by Equifax's poorly implemented breach site.) Maybe this vague address was a temporary quick fix, and Marriott will host a comprehensive breach-status site later on one of its servers. That would be better and clearer for affected customers, who probably are unfamiliar with Kroll. Readers of this blog probably first encountered Kroll after IBM Inc. contracted it to help implement IBM's post-breach response in 2007.

The Starwood breach notice appears within the news section of Marriott.com site. Also, Marriott's post-breach notice included overlays on both the home page and the Starwood landing page within the Marriott.com site. This is a good start, but a better implementation would insert a link directly into the webpages, since the overlays don't render well in all browsers on all devices. (Marriott: you did test this before deployment?) Example: people with pop-up blockers may miss the breach notice in the overlays. And, a better implementation would link to the news story's detail page within the Marriott.com site -- not directly to the vague answers.kroll.com site.

Last, some questions remain about the post-breach response:

  • Why email notices to breach victims? Hopefully, there are more reasons than simply saving postal mailing costs.
  • Why no credit monitoring offers to breach victims?
  • What data in the Starwood reservations database was altered by the attackers? That data was encrypted by the attackers suggests that the attackers had sufficient time, resources, and skills to modify or alter database records. Marriott needs to explain what it is doing about this.
  • When will Marriott host a breach site on one of its servers? No doubt, there will be follow-up news, more questions by breach victims, and breach investigation updates. A dedicated breach site on one of its servers seems best. Leaning too much on Kroll is not good.
  • Why did the intrusion go undetected for so long? Marriott needs to explain this and the post-breach fix so guests are reassured it won't happen again.
  • Is the main Marriott reservations database also vulnerable? Guests for other brands weren't affected since a separate reservations database was used. Maybe this is because the main Marriott reservations database and server are better protected, or cybercriminals haven't attacked it (yet). Guests deserve comprehensive answers.
  • Why the website overlaps/pop-ups and not static links?
  • What changes (e.g., software upgrades, breach detection tools, employee training, etc.) will be implemented so this doesn't happen again?

Having blogged about data breaches for 11+ years, these types of questions often arise. None are unreasonable questions. Answers will help guests feel comfortable with using Starwood hotels. Plus, Marriott has an obligation to fully inform guests directly at its website, and not lean on Kroll. What do you think?


Amazon Said Its Data Breach Was Due To A "Technical Error" And Discloses Few Breach Details

Amazon logo Amazon.com, the online retail giant, confirmed that it experienced a data breach last Wednesday. CBS News reported:

"Amazon said a technical error on its website exposed the names and email addresses of some customers. The online retail giant its website and systems weren't hacked. "We have fixed the issue and informed customers who may have been impacted," said an Amazon spokesperson. An Amazon spokesman didn't answer additional questions, like how many people were affected or whether any of the information was stolen."

A check of the press center and blog sections with the Amazon.com site failed to find any mentions of the data breach. The Ars Technica blog posted the text of the breach notification email Amazon sent to affected users:

"From: Amazon.com
Sent: 21 November 2018 10:53
To: a--------l@hotmail.com
Subject: Important Information about your Amazon.com Account

Hello,
We’re contacting you to let you know that our website inadvertently disclosed your name and email address due to a technical error. The issue has been fixed. This is not a result of anything you have done, and there is no need for you to change your password or take any other action.

Sincerely,
Customer Service
http://Amazon.com"

What? That's all? No link to a site or to a page for customers with questions?

This incident is a reminder that several things can cause data breaches. It's not only when cyber-criminals break into an organization's computers or systems. Human error causes data breaches, too. In some breaches, employees collude with criminals. In some cases, sloppy data security by outsource vendors causes data breaches. Details matter.

Typically, organizations affected by data breaches hire external security agencies to conduct independent, post-breach investigations to learn important details: when the breach started, how exactly the breach happened, the list of data elements unauthorized users accessed/stole, what else may have happened that wasn't readily apparent when the incident was discovered, and key causal events leading up to the breach -- all so that a complete fix can be implemented, and so that it doesn't happen again.

Who made the "technical error?" Who discovered it? What caused it? How long did the error exist? Who fixed it? Were specialized skills or tools necessary? What changes were made so that it won't happen again? Amazon isn't saying. If management decided to skip a post-breach investigation, consumers deserve to know that and why, too.

Often, the breach starts long before it is discovered by the company, or by a security researcher. Often, the fix includes several improvements: software changes, employee training, and/or improved security processes with contractors.

So, all we know is that names and email addresses were accessed by unauthorized persons. If stolen, that is sufficient to do damage -- spam or phishing email messages, to trick victims into revealing sensitive personal (e.g., usernames, passwords, etc.) and payment (e.g., bank account numbers, credit card numbers, etc.) information. It is not too much to ask Amazon to share both breach details and the results of a post-breach investigation.

Executives at Amazon know all of this, so maybe it was a management decision not to share breach details nor a post-breach investigation -- perhaps, not wanting to risk huge Black Friday holiday sales. Then again, the lack of details could imply the breach was far worse than management wants to admit.

Either way, this is troublesome. It's all about trust. When details are shared, consumers can judge the severity of the breach, the completeness of the company's post-breach response, and ideally feel better about continuing to shop at the site. What do you  think?


Data Breach Affects 75,000 Healthcare.gov Users

On Friday, the Centers For Medicare and Medicaid Services (CMS) announced a data breach at a computer system which interacts with the Healthcare.gov site. Files for about 75,000 users -- agents and brokers -- were accessed by unauthorized persons. The announcement stated:

"Earlier this week, CMS staff detected anomalous activity in the Federally Facilitated Exchanges, or FFE’s Direct Enrollment pathway for agents and brokers. The Direct Enrollment pathway, first launched in 2013, allows agents and brokers to assist consumers with applications for coverage in the FFE... CMS began the initial investigation of anomalous system activity in the Direct Enrollment pathway for agents and brokers on October 13, 2018 and a breach was declared on October 16, 2018. The agent and broker accounts that were associated with the anomalous activity were deactivated, and – out of an abundance of caution – the Direct Enrollment pathway for agents and brokers was disabled."

CMS has notified and is working with Federal law enforcement. It expects to restore the Direct Enrollment pathway for agents and brokers within the next 7 days, before the start of the sign-up period on November 1st for health care coverage under the Affordable Care Act.

CMS Administrator Seema Verma said:

"I want to make clear to the public that HealthCare.gov and the Marketplace Call Center are still available, and open enrollment will not be negatively impacted. We are working to identify the individuals potentially impacted as quickly as possible so that we can notify them and provide resources such as credit protection."

Sadly, data breaches happen -- all too often within government agencies and corporations. It should be noted that this breach was detected quickly -- within 3 days. Other data breaches have gone undetected for weeks or months; and too many corporate data breaches affected millions.

 


Facebook Data Breach Affected 90 Million Users. Users Claim Facebook Blocked Posts About the Breach

On Friday, Facebook announced a data breach which affected about 50 million users of the social networking service. Facebook engineers discovered the hack on September 25th. The Facebook announcement explained:

"... that attackers exploited a vulnerability in Facebook’s code that impacted “View As” a feature that lets people see what their own profile looks like to someone else. This allowed them to steal Facebook access tokens which they could then use to take over people’s accounts. Access tokens are the equivalent of digital keys that keep people logged in to Facebook so they don’t need to re-enter their password every time they use the app... This attack exploited the complex interaction of multiple issues in our code. It stemmed from a change we made to our video uploading feature in July 2017, which impacted “View As.” The attackers not only needed to find this vulnerability and use it to get an access token, they then had to pivot from that account to others to steal more tokens."

Facebook Security Update: image for mobile users. Click to view larger version Many mobile users will see the message in the image displayed on the right. Facebook said it has fixed the vulnerability, notified law enforcement, turned off the "View As" feature until the breach investigation is finished, and has already reset the access tokens of about 90 million users.

Why the higher number of 90 million and not 50 million? According to the announcement:

"... we have reset the access tokens of the almost 50 million accounts we know were affected to protect their security. We’re also taking the precautionary step of resetting access tokens for another 40 million accounts that have been subject to a “View As” look-up in the last year. As a result, around 90 million people will now have to log back in to Facebook, or any of their apps that use Facebook Login. After they have logged back in, people will get a notification at the top of their News Feed explaining what happened."

So, 90 million users affected and 50 million known for sure. What to make of this? Wait for findings in the completed breach investigation. Until then, we won't know exactly how attackers broke in, what they stole, and the true number of affected users.

What else to make of this? Facebook's announcement skillfully avoided any direct mentions of exactly when the attack started. The announcement stated that the vulnerability was related to a July 2017 change to the video uploading feature. So, the attack could have started soon after that. Facebook didn't say, and it may not know. Hopefully, the final breach investigation report will clarify things.

And, there is more disturbing news.

Some users have claimed that Facebook blocked them from posting messages about the data breach. TechCrunch reported:

"Some users are reporting that they are unable to post [the] story about a security breach affecting 50 million Facebook users. The issue appears to only affect particular stories from certain outlets, at this time one story from The Guardian and one from the Associated Press, both reputable press outlets... some users, including members of the staff here at TechCrunch who were able to replicate the bug, were met with the following error message which prevented them from sharing the story."

Error message displayed to some users trying to post about Facebook data breach. Click to view larger version

Well, we now know that -- for better or for worse -- Facebook has an automated tool to identify spam content in real-time. And, this tool can easily misidentify content as spam, which isn't spam. Not good.

Reportedly, this error message problem has been fixed. Regardless, it should never have happened. The data breach is big news. Clearly, many people want to read and post about it. Popularity does not indicate spam. And Facebook owes users an explanation about its automated tool.

Did Facebook notify you directly of its data breach? Did you get this spam error message? How concerned are you? Please share your experience and opinions below.


T-Mobile Confirmed Data Breach Affecting Millions Of Customers

T-Mobile logo T-Mobile confirmed a data breach which impacted its customers. Last week, the mobile service provider said in a statement:

"On August 20, our cyber-security team discovered and shut down an unauthorized access to certain information, including yours, and we promptly reported it to authorities. None of your financial data (including credit card information) or social security numbers were involved, and no passwords were compromised. However, you should know that some of your personal information may have been exposed, which may have included one or more of the following: name, billing zip code, phone number, email address, account number and account type (prepaid or postpaid)."

Affected customers are being notified. The statement did not disclose the number of affected customers, exactly how criminals breached its systems, nor the specific actions T-Mobile is taking to prevent this type of breach from happening again. The lack of detail is discouraging and does not promote trust.

CBS News reported:

"... the breach affected about 3 percent of T-Mobile's 77 million customers, or 2 million people... In May, researchers detected a bug in the company's website that allowed anyone to access the personal data of customers with just a phone number. The company is waiting for regulatory approval of a proposed $26.5 billion takeover of Sprint, the fourth-largest carrier in the United States."

So, criminals have stolen enough information to do damage: send spam via e-mail or text, and conduct pretexting (e.g., impersonate others to take over online accounts by resetting passwords, and/or gain access to payment data).

If you received a breach notice from T-Mobile, how satisfied are you with the company's response?


Adidas Announced A 'Potential' Data Breach Affecting Online Shoppers in the United States

Adidas announced on June 28 a "potential" data breach affecting an undisclosed number of:

"... consumers who purchased on adidas.com/US... On June 26, Adidas became aware that an unauthorized party claims to have acquired limited data associated with certain Adidas consumers. Adidas is committed to the privacy and security of its consumers' personal data. Adidas immediately began taking steps to determine the scope of the issue and to alert relevant consumers. adidas is working with leading data security firms and law enforcement authorities to investigate the issue..."

The preliminary breach investigation found that contact information, usernames, and encrypted passwords were exposed or stolen. So far, no credit card or fitness information of consumers was "impacted." The company said it is continuing a forensic review and alerting affected customers.

While the company's breach announcement did not disclose the number of affected customer, CBS News reported that hackers may have stolen data about millions of customers. Fox Business reported that the Adidas:

"... hack was reported weeks after Under Armour’s health and fitness app suffered a security breach, which exposed the personal data of roughly 150 million users. The revealed information included the usernames, hashed passwords and email addresses of MyFitnessPal users."

It is critical to remember that this June 28th announcement was based upon a preliminary investigation. A completed breach investigation will hopefully determine and disclose any additional data elements exposed (or stolen), how the hackers penetrated the company's computer systems, which systems were penetrated, whether any internal databases were damaged/corrupted/altered, the total number of customers affected, specific fixes implemented so this type of breach doesn't happen again, and descriptive information about the cyber criminals.

This incident is also a reminder to consumers to never reuse the same password at several online sites. Cyber criminals are persistent, and will use the same password at several sites to see where else they can get in. It is no relief that encrypted passwords were stolen, because we don't yet know if the encryption tools were also stolen (making it easy for the hackers to de-encrypt the passwords). Not good.

We also don't yet know what "contact information" means. That could be first name, last name, phone, street address, e-mail address, mobile phone numbers, or some combination. If e-mail addresses were stolen, then breach victims could also experience phishing attacks where fraudsters try to trick victims into revealing bank account, sign-in credentials, and other sensitive information.

If you received a breach notice from Adidas, please share it below while removing any sensitive, identifying information.


Several States Updated Their Existing Breach Notification Laws, Or Introduced New Laws

Given the increased usage of data in digital formats, new access methods, and continual data breaches within corporations and governments, several state governments have updated their data breach notification laws, and/or passed new laws:

Alabama

The last state without any breach notification laws, Governor Kay Ivey signed in March the state's first data breach law: the Alabama Data Breach Notification Act of 2018 (SB 318), which became effective on June 1, 2018. Some of the key modifications: a) similar to other states, the law defined the format and types of data elements which must be protected, including health information; b) defined "covered entities" including state government agencies and "third-party agents" contracted to maintain, store, process and/or access protected data; c) requires notification of affected individuals within 45 days, and to the state Attorney General; and d) while penalties aren't mandatory, the law allows civil penalties up to $5,000 per day for, "each consecutive day that the covered entity fails to take reasonable action to comply with the notice provisions of this act."

Arizona

Earlier this year, Arizona Governor Doug Ducey signed legislation updating the state's breach notification laws. Some of the key modifications: a) expanded definitions of personal information to include medical or mental health treatment/diagnosis, passport numbers, taxpayer ID numbers, biometric data, e-mail addresses in combination with online passwords and security questions; b) set the notification window for affected persons at 45 days; c) allows e-mail notification of affected persons; d) and if the breach affected more than 1,000 persons, then notification must provided to the three national credit-reporting agencies and to the state Attorney General.

Colorado

Colorado Governor John Hickenloope signed on May 29th several laws including HB-1128, which will go into effect on september 1, 2018. Some experts view HB-1128 as the strongest protections in the country. Some of the key modifications: a) expanded "covered entities" to include certain "third-party service providers" contracted to maintain, store, process and/or access protected data; b) expanded definitions of "personal information" to include biometric data, plus e-mail addresses in combination with online passwords and security questions; c) allows substitute notification methods (e.g., e-mail, post on website, statewide news media) if the cost of basic notification would exceed $250,000; d) allows e-mail notification of affected persons; e) sets the notification window at 30 days, if the breach affected more than 500 Colorado residents; and f) expanded requirements for companies to protected personal information.

Louisiana

Louisiana Governor John Edwards signed in May 2018 an amendment to the state’s Database Security Breach Notification Law (Act 382) which will take effect August 1, 2018. Some of the key modifications: a) expanded definition of ‘personal information’ to include a state identification card number, passport number, and “biometric data” (e.g., fingerprints, voice prints, eye retina or iris, or other unique biological characteristics used to access systems); b) removed vagueness and defined the notification window as within 60 days; c) allows substitute notification methods (e.g., e-mail, posts on affected company's website, statewide news media); and d) tightened required that companies utilizing "computerized data" better protect the information they archive.

South Dakota

The next-to-last state without any breach notification laws, Governor Dennis Daugaard signed into law in March the state’s first breach notification law (SB 62). Like breach laws in other states, it provides definitions of what a breach is, personal information which must be protected, covered entities (e.g., companies, government agencies) subject to the law, notification requirements, and conditions when substitute notification methods (e.g., e-mail, posts on the affected entity's website, statewide news media) are allowed.

To Summarize

New Mexico enacted its new breach notification law (HB 15) in March, 2017. With the additions of Alabama and South Dakota, finally every state has a breach notification law. Sadly, it has taken 16 years. California was the first state to enact a breach notification law in 2002. It has taken that long for other states to catch up... not only catch up with California, but also catch up with technological changes driven by the internet.

California has led the way for a long time. It banned RFID skimming in 2008, co-hosted privacy workshops with the U.S. Federal Trade Commission in 2008, strengthened its existing breach law in 2011, and introduced in 2013 privacy guidelines for mobile app developers. Other states' legislatures can learn from this leadership.

Want to learn more? Detailed reviews of new and updated breach laws are available in the National Law Review website.


How To Check If Your Information Was Collected By Cambridge Analytica In The Facebook Breach

You've probably heard about the massive privacy and data security breach at Facebook.com where users' information, plus their friends' information was captured and shared with Cambridge Analytica. by an app created by an academic professor. Now, you want to know if your information was harvested.

How To Check

It's easy to check. Visit this Facebook Help Center page. If you are not signed into your Facebook account, then the page displays as:

Default version of Facebook Help page for users to determine if their information was collected by Cambridge Analytica. Click to view larger version

If you have already signed into your Facebook account and your information was not harvested, then the main column of the page displays:

Default version of Facebook Help page for users to determine if their information was collected by Cambridge Analytica. Click to view larger version

If your information was harvested, then the content under "Was My Information Shared?" will be different. It may display this:

"Based upon our investigation, you don't appear to have logged into "This Is Your Digital Life" with Facebook before we removed it from our platform in 2015. However, a friend of yours did log in. As a result, the following information was likely shared with "This Is Your Digital Life": Your public profile, page likes, date of birth, and current city"

Of course, if you logged into the "This Is Your Digital Life" app yourself, then the page content will say so, and list the data elements harvested. Reportedly, about 270,000 Facebook users logged into the app/quiz which then collected information for an estimated 87 million of those users' Facebook friends.

What To Do Next

There's not a lot you can do immediately. CNN Tech advised:

"Even if you delete your Facebook account, or remove third-party apps connected to your profile, the third-party apps will still have access to data they previously collected. Users have to contact the app individually to have the data be removed... According to a notice on affected accounts, the "small number of people" who accessed the app also shared their News Feed, timeline, posts and messages. A Facebook spokesperson confirmed that 1,500 users who logged into the app granted explicit access to their private message inbox... For now, the platform is directing people to their Settings page to see which apps are connected to their accounts, such as Uber and Netflix. Users can also disconnect those apps... Walt Mossberg, a veteran tech reporter and cofounder of tech website Recode, urged Facebook to let users know which friends accessed the app and when..."

Yeah, that! Facebook should inform affected users which of their friends contributed to the data leakage.

Of course, Facebook wants its users to keep using the service. Facebook announced on March 21st that it will, 1) investigate all apps that had access to large amounts of information and conduct full audits of any apps with suspicious activity; 2) inform users affected by apps that have misused their data; 3) disable an app's access to a member's information if that member hasn't used the app within the last three months; 4) change Login to "reduce the data that an app can request without app review to include only name, profile photo and email address;" 5) encourage members to manage the apps they use; and reward users who find vulnerabilities.

Those actions seem good, but too little too late. What can affected users do?

You have options. If you use Facebook, see these instructions by Consumer Reports to deactivate or delete your account. Some people I know simply stopped using Facebook, but left their accounts active. That doesn't seem wise. A better approach is to adjust the privacy settings on your Facebook account to get as much privacy and protections as possible.

Facebook has a new tool for members to review and disable, in bulk, all of the apps with access to their data. Follow these handy step-by-step instructions by Mashable. And, users should also disable the Facebook API platform for their account. If you use the Firefox web browser, then install the new Facebook Container add-on specifically designed to prevent Facebook from tracking you. Don't use Firefox? You might try the Privacy Badger add-on instead. I've used it happily for years.

Whatever you do, remember that lots of advertising networks and tech companies besides Facebook want to track your movements around the web. Some of those companies include internet service providers (ISPs), since the U.S. Federal Communications Commission (FCC) killed both broadband privacy and net neutrality in 2017.

A windfall for broadband providers, and terrible for consumers. You might contact your elected officials and demand that the FCC put broadband privacy and net neutrality protections back into place.


Security Experts: Breach At Panera Bread Affected Millions. Questions Linger About Vulnerability Fix

Panera Bread logo Apparently, Panera Bread experienced a massive data breach, which the restaurant chain's management allegedly ignored for months. CSO Online reported:

"Panera Bread’s website leaked millions of customer records in plain text for at least eight months, which is how long the company blew off the issues reported by security researcher Dylan Houlihan... Houlihan shared copies of email exchanges with Panera Bread CIO John Meister – who at first accused Houlihan of trying to run a scam when he first reported the security vulnerability back in August 2017... Exactly eight months after reporting the issue to Panera Bread, Houlihan turned to KrebsOnSecurity. Krebs spoke to Meister, and the website was briefly taken offline. Less than two hours later, Panera said it had fixed the problem."

Reportedly, the sensitive customer information leaked included usernames, first and last names, email addresses, phone numbers, home addresses, birthdays, the last four digits of saved credit card numbers, dietary restrictions, food preferences, and "social account integration information."

Security experts disagree about two key issues: a) whether or not the vulnerability was fixed, and b) the number of affected consumers. Panera Bread claimed about 10,000 customers were affected. Then, that number went up:

"After some more poking, Hold Security reported to Krebs that Panera didn’t just leak plain text records of 7 million customers; “the vulnerabilities also appear to have extended to Panera’s commercial division, which serves countless catering companies. At last count, the number of customer records exposed in this breach appears to exceed 37 million.”

A check earlier today of the public-facing pages at Panera's website failed to find a breach notice, which companies usually provide after a data breach. Not good. Shoppers need to know. Many states have breach notification laws.

Panera's behavior doesn't inspire much confidence. It's internal breach-detection mechanisms seem to have failed, and its post-breach response seemed unprepared, unfocused, and disinterested. What do you think?


Facebook Update: 87 Million Affected By Its Data Breach With Cambridge Analytica. Considerations For All Consumers

Facebook logo Facebook.com has dominated the news during the past three weeks. The news media have reported about many issues, but there are more -- whether or not you use Facebook. Things began about mid-March, when Bloomberg reported:

"Yes, Cambridge Analytica... violated rules when it obtained information from some 50 million Facebook profiles... the data came from someone who didn’t hack the system: a professor who originally told Facebook he wanted it for academic purposes. He set up a personality quiz using tools that let people log in with their Facebook accounts, then asked them to sign over access to their friend lists and likes before using the app. The 270,000 users of that app and their friend networks opened up private data on 50 million people... All of that was allowed under Facebook’s rules, until the professor handed the information off to a third party... "

So, an authorized user shared members' sensitive information with unauthorized users. Facebook confirmed these details on March 16:

"We are suspending Strategic Communication Laboratories (SCL), including their political data analytics firm, Cambridge Analytica (CA), from Facebook... In 2015, we learned that a psychology professor at the University of Cambridge named Dr. Aleksandr Kogan lied to us and violated our Platform Policies by passing data from an app that was using Facebook Login to SCL/CA, a firm that does political, government and military work around the globe. He also passed that data to Christopher Wylie of Eunoia Technologies, Inc.

Like all app developers, Kogan requested and gained access to information from people after they chose to download his app. His app, “thisisyourdigitallife,” offered a personality prediction, and billed itself on Facebook as “a research app used by psychologists.” Approximately 270,000 people downloaded the app. In so doing, they gave their consent for Kogan to access information such as the city they set on their profile, or content they had liked... When we learned of this violation in 2015, we removed his app from Facebook and demanded certifications from Kogan and all parties he had given data to that the information had been destroyed. CA, Kogan and Wylie all certified to us that they destroyed the data... Several days ago, we received reports that, contrary to the certifications we were given, not all data was deleted..."

So, data that should have been deleted wasn't. Then, Facebook relied upon certifications from entities that had lied previously. Not good. Then, Facebook posted this addendum on March 17:

"The claim that this is a data breach is completely false. Aleksandr Kogan requested and gained access to information from users who chose to sign up to his app, and everyone involved gave their consent. People knowingly provided their information, no systems were infiltrated, and no passwords or sensitive pieces of information were stolen or hacked."

Why the rush to deny a breach? It seems wise to complete a thorough investigation before making such a claim. In the 11+ years I've written this blog, whenever unauthorized persons access data they shouldn't have, it's a breach. You can read about plenty of similar incidents where credit reporting agencies sold sensitive consumer data to ID-theft services and/or data brokers, who then re-sold that information to criminals and fraudsters. Seems like a breach to me.

Cambridge Analytica logo Facebook announced on March 19th that it had hired a digital forensics firm:

"... Stroz Friedberg, to conduct a comprehensive audit of Cambridge Analytica (CA). CA has agreed to comply and afford the firm complete access to their servers and systems. We have approached the other parties involved — Christopher Wylie and Aleksandr Kogan — and asked them to submit to an audit as well. Mr. Kogan has given his verbal agreement to do so. Mr. Wylie thus far has declined. This is part of a comprehensive internal and external review that we are conducting to determine the accuracy of the claims that the Facebook data in question still exists... Independent forensic auditors from Stroz Friedberg were on site at CA’s London office this evening. At the request of the UK Information Commissioner’s Office, which has announced it is pursuing a warrant to conduct its own on-site investigation, the Stroz Friedberg auditors stood down."

That's a good start. An audit would determine or not data which perpetrators said was destroyed, actually had been destroyed. However, Facebook seems to have built a leaky system which allows data harvesting:

"Hundreds of millions of Facebook users are likely to have had their private information harvested by companies that exploited the same terms as the firm that collected data and passed it on to CA, according to a new whistleblower. Sandy Parakilas, the platform operations manager at Facebook responsible for policing data breaches by third-party software developers between 2011 and 2012, told the Guardian he warned senior executives at the company that its lax approach to data protection risked a major breach..."

Reportedly, Parakilas added that Facebook, "did not use its enforcement mechanisms, including audits of external developers, to ensure data was not being misused." Not good. The incident makes one wonder what other developers, corporate, and academic users have violated Facebook's rules: shared sensitive Facebook members' data they shouldn't have.

Facebook announced on March 21st that it will, 1) investigate all apps that had access to large amounts of information and conduct full audits of any apps with suspicious activity; 2) inform users affected by apps that have misused their data; 3) disable an app's access to a member's information if that member hasn't used the app within the last three months; 4) change Login to "reduce the data that an app can request without app review to include only name, profile photo and email address;" 5) encourage members to manage the apps they use; and reward users who find vulnerabilities.

Those actions seem good, but too little too late. Facebook needs to do more... perhaps, revise its Terms Of Use to include large fines for violators of its data security rules. Meanwhile, there has been plenty of news about CA. The Guardian UK reported on March 19:

"The company at the centre of the Facebook data breach boasted of using honey traps, fake news campaigns and operations with ex-spies to swing election campaigns around the world, a new investigation reveals. Executives from Cambridge Analytica spoke to undercover reporters from Channel 4 News about the dark arts used by the company to help clients, which included entrapping rival candidates in fake bribery stings and hiring prostitutes to seduce them."

Geez. After these news reports surfaced, CA's board suspended Alexander Nix, its CEO, pending an internal investigation. So, besides Facebook's failure to secure sensitive members' information, another key issue seems to be the misuse of social media data by a company that openly brags about unethical, and perhaps illegal, behavior.

What else might be happening? The Intercept explained on March 30th that CA:

"... has marketed itself as classifying voters using five personality traits known as OCEAN — Openness, Conscientiousness, Extroversion, Agreeableness, and Neuroticism — the same model used by University of Cambridge researchers for in-house, non-commercial research. The question of whether OCEAN made a difference in the presidential election remains unanswered. Some have argued that big data analytics is a magic bullet for drilling into the psychology of individual voters; others are more skeptical. The predictive power of Facebook likes is not in dispute. A 2013 study by three of Kogan’s former colleagues at the University of Cambridge showed that likes alone could predict race with 95 percent accuracy and political party with 85 percent accuracy. Less clear is their power as a tool for targeted persuasion; CA has claimed that OCEAN scores can be used to drive voter and consumer behavior through “microtargeting,” meaning narrowly tailored messages..."

So, while experts disagree about the effectiveness of data analytics with political campaigns, it seems wise to assume that the practice will continue with improvements. Data analytics fueled by social media input means political campaigns can bypass traditional news media outlets to distribute information and disinformation. That highlights the need for Facebook (and other social media) to improve their data security and compliance audits.

While the UK Information Commissioner's Office aggressively investigates CA, things seem to move at a much slower pace in the USA. TechCrunch reported on April 4th:

"... Facebook’s founder Mark Zuckerberg believes North America users of his platform deserve a lower data protection standard than people everywhere else in the world. In a phone interview with Reuters yesterday Mark Zuckerberg declined to commit to universally implementing changes to the platform that are necessary to comply with the European Union’s incoming General Data Protection Regulation (GDPR). Rather, he said the company was working on a version of the law that would bring some European privacy guarantees worldwide — declining to specify to the reporter which parts of the law would not extend worldwide... Facebook’s leadership has previously implied the product changes it’s making to comply with GDPR’s incoming data protection standard would be extended globally..."

Do users in the USA want weaker data protections than users in other countries? I think not. I don't. Read for yourself the April 4th announcement by Facebook about changes to its terms of service and data policy. It didn't mention specific countries or regions; who gets what and where. Not good.

Mark Zuckerberg apologized and defended his company in a March 21st post:

"I want to share an update on the Cambridge Analytica situation -- including the steps we've already taken and our next steps to address this important issue. We have a responsibility to protect your data, and if we can't then we don't deserve to serve you. I've been working to understand exactly what happened and how to make sure this doesn't happen again. The good news is that the most important actions to prevent this from happening again today we have already taken years ago. But we also made mistakes, there's more to do, and we need to step up and do it... This was a breach of trust between Kogan, Cambridge Analytica and Facebook. But it was also a breach of trust between Facebook and the people who share their data with us and expect us to protect it. We need to fix that... at the end of the day I'm responsible for what happens on our platform. I'm serious about doing what it takes to protect our community. While this specific issue involving Cambridge Analytica should no longer happen with new apps today, that doesn't change what happened in the past. We will learn from this experience to secure our platform further and make our community safer for everyone going forward."

Nice sounding words, but actions speak louder. Wired magazine said:

"Zuckerberg didn't mention in his Facebook post why it took him five days to respond to the scandal... The groundswell of outrage and attention following these revelations has been greater than anything Facebook predicted—or has experienced in its long history of data privacy scandals. By Monday, its stock price nosedived. On Tuesday, Facebook shareholders filed a lawsuit against the company in San Francisco, alleging that Facebook made "materially false and misleading statements" that led to significant losses this week. Meanwhile, in Washington, a bipartisan group of senators called on Zuckerberg to testify before the Senate Judiciary Committee. And the Federal Trade Commission also opened an investigation into whether Facebook had violated a 2011 consent decree, which required the company to notify users when their data was obtained by unauthorized sources."

Frankly, Zuckerberg has lost credibility with me. Why? Facebook's history suggests it can't (or won't) protect users' data it collects. Some of its privacy snafus: settlement of a lawsuit resulting from alleged privacy abuses by its Beacon advertising program, changed members' ad settings without notice nor consent, an advertising platform which allegedly facilitates abuses of older workers, health and privacy concerns about a new service for children ages 6 to 13, transparency concerns about political ads, and new lawsuits about the company's advertising platform. Plus, Zuckerberg made promises in January to clean up the service's advertising. Now, we have yet another apology.

In a press release this afternoon, Facebook revised upward the number affected by the Facebook/CA breach from 50 to 87 million persons. Most, about 70.6 million, are in the United States. The breakdown by country:

Number of affected persons by country in the Facebook - Cambridge Analytica breach. Click to view larger version

So, what should consumers do?

You have options. If you use Facebook, see these instructions by Consumer Reports to deactivate or delete your account. Some people I know simply stopped using Facebook, but left their accounts active. That doesn't seem wise. A better approach is to adjust the privacy settings on your Facebook account to get as much privacy and protections as possible.

Facebook has a new tool for members to review and disable, in bulk, all of the apps with access to their data. Follow these handy step-by-step instructions by Mashable. And, users should also disable the Facebook API platform for their account. If you use the Firefox web browser, then install the new Facebook Container new add-on specifically designed to prevent Facebook from tracking you. Don't use Firefox? You might try the Privacy Badger add-on instead. I've used it happily for years.

Of course, you should submit feedback directly to Facebook demanding that it extend GDPR privacy protections to your country, too. And, wise online users always read the terms and conditions of all Facebook quizzes before taking them.

Don't use Facebook? There are considerations for you, too; especially if you use a different social networking site (or app). Reportedly, Mark Zuckerberg, the CEO of Facebook, will testify before the U.S. Congress on April 11th. His upcoming testimony will be worth monitoring for everyone. Why? The outcome may prod Congress to act by passing new laws giving consumers in the USA data security and privacy protections equal to what's available in the United Kingdom. And, there may be demands for Cambridge Analytica executives to testify before Congress, too.

Or, consumers may demand stronger, faster action by the U.S. Federal Trade Commission (FTC), which announced on March 26th:

"The FTC is firmly and fully committed to using all of its tools to protect the privacy of consumers. Foremost among these tools is enforcement action against companies that fail to honor their privacy promises, including to comply with Privacy Shield, or that engage in unfair acts that cause substantial injury to consumers in violation of the FTC Act. Companies who have settled previous FTC actions must also comply with FTC order provisions imposing privacy and data security requirements. Accordingly, the FTC takes very seriously recent press reports raising substantial concerns about the privacy practices of Facebook. Today, the FTC is confirming that it has an open non-public investigation into these practices."

An "open non-public investigation?" Either the investigation is public, or it isn't. Hopefully, an attorney will explain. And, that announcement read like weak tea. I expect more. Much more.

USA citizens may want stronger data security laws, especially if Facebook's solutions are less than satisfactory, it refuses to provide protections equal to those in the United Kingdom, or if it backtracks later on its promises. Thoughts? Comments?


Update: 2.4 Million More Persons Affected By Massive Data Breach At Equifax In 2017

Equifax logo Equifax, one of the three national credit reporting agencies, announced today that 2.4 million more persons were affected by its massive data breach in 2017. The March 1st announcement stated, in part:

"Equifax Inc. today announced that the company has confirmed the identities of U.S. consumers whose partial driver’s license information was taken. Equifax was able to identify these consumers by referencing other information in proprietary company records that the attackers did not steal, and by engaging the resources of an external data provider.

Through these additional efforts, Equifax was able to identify approximately 2.4 million U.S. consumers whose names and partial driver’s license information were stolen, but who were not in the previously identified affected population discussed in the company’s prior disclosures about the incident. This information was partial because, in the vast majority of cases, it did not include consumers’ home addresses, or their respective driver’s license states, dates of issuance, or expiration dates... Today’s newly identified consumers were not previously informed because their SSNs were not stolen together with their partial driver’s license information..."

Equifax will notify the newly identified breach victims via U.S. Postal mail, and will offer them complimentary identity theft protection and credit file monitoring services.

The timeline for the massive breach: intrusions occurred in May (2017), Equifax staff first discovered the intrusions in July (2017); Equifax notified the publicy in September (2017); and now identified 2.4 million more breach victims (March, 2018).

Equifax said in September (2017) that 143 million persons were affected. That was about 44 percent of the United States population. In October (2017), Equifax revised upward the number affected by 2.5 million to 145.5 million persons. What's the new total? Equifax didn't have the guts to admit it in its March 1st announcement. Since the company doesn't seem to want to admit it, I'm going with 147.9 million persons affected -- about 45.6 percent of the population.

So, it took Equifax almost six months after its initial announcement to determine exactly who was affected during its massive data breach. This does not inspire confidence. Instead, it suggests that the company's internal systems and intrusion detection mechanisms failed miserably.

A breach investigation by U.S. Senator Elizabeth Warren (Democrat - Massachusetts) reported several failures:

  1. Equifax Set up a Flawed System to Prevent and Mitigate Data Security Problems
  2. Equifax Ignored Numerous Warnings of Risks to Sensitive Data
  3. Equifax Failed to Notify Consumers, Investors, and Regulators about the Breach in a Timely and Appropriate Fashion
  4. Equifax Took Advantage of Federal Contracting Loopholes and Failed to Adequately Protect Sensitive IRS Taxpayer Data
  5. Equifax’s Assistance and Information Provided to Consumers Following the Breach was Inadequate.

Equifax's latest breach update highlights item #3: the company's failure to promptly notify consumers. When consumers aren't notified promptly, they are unable to take action to protect their sensitive personal and payment information.

Have we heard the last from Equifax? Will it provide future updates with even more persons affected? I hope not, but the company's track record suggests otherwise.

Equifax has foisted upon the country a cluster f--k of epic proportions = #FUBAR. Businesses and consumers depend upon secure, reliable credit reports. The United States economy relies upon it, too. Equifax executives need to experience direct consequences: fines, terminations, and jail time. Without consequences, executives won't adequately secure sensitive personal and financial information -- and this will happen again. What do you think?


Uber: Data Breach Affected 57 Million Users. Some Say A Post Breach Coverup, Too

Uber logo Uber is in the news again. And not in a good way. The popular ride-sharing service experienced a data breach affecting 57 million users. While many companies experience data breaches, regulators say Uber went further and tried to cover it up.

First, details about the data breach. Bloomberg reported:

"Hackers stole the personal data of 57 million customers and drivers... Compromised data from the October 2016 attack included names, email addresses and phone numbers of 50 million Uber riders around the world, the company told Bloomberg on Tuesday. The personal information of about 7 million drivers was accessed as well, including some 600,000 U.S. driver’s license numbers..."

Second, details about the coverup:

"... the ride-hailing firm ousted its chief security officer and one of his deputies for their roles in keeping the hack under wraps, which included a $100,000 payment to the attackers... At the time of the incident, Uber was negotiating with U.S. regulators investigating separate claims of privacy violations. Uber now says it had a legal obligation to report the hack to regulators and to drivers whose license numbers were taken. Instead, the company paid hackers to delete the data and keep the breach quiet."

Geez. Not tell regulators about a breach? Not tell affected users? 48 states have data breach notification laws requiring various levels of notifications. Consumers need notice in order to take action to protect themselves and their sensitive personal and payment information.

Third, Uber executives learned about the breach soon thereafter:

"Kalanick, Uber’s co-founder and former CEO, learned of the hack in November 2016, a month after it took place, the company said. Uber had just settled a lawsuit with the New York attorney general over data security disclosures and was in the process of negotiating with the Federal Trade Commission over the handling of consumer data. Kalanick declined to comment on the hack."

Reportedly, breach victims with stolen drivers license information will be offered free credit monitoring and identity theft services. Uber said that no Social Security numbers and credit card information was stolen during the breach, but one wonders if Uber and its executives can be trusted.

The company has a long history of sketchy behavior including the 'Greyball' worldwide program by executives to thwart code enforcement inspections by governments, dozens of employees fired or investigated for sexual harassment, a lawsuit descrbing how the company's mobile app allegedly scammed both riders and drivers, and privacy abuses with the 'God View' tool. TechCrunch reported that Uber:

"... reached a settlement with [New York State Attorney General] Schneiderman’s office in January 2016 over its abuse of private data in a rider-tracking system known as “God View” and its failure to disclose a previous data breach that took place in September 2014 in a timely manner."

Several regulators are investigating Uber's latest breach and alleged coverup. CNet reported:

"The New York State Attorney General has opened an investigation into the incident, which Uber made public Tuesday. Officials for Connecticut, Illinois and Massachusetts also confirmed they're investigating the hack. The New Mexico Attorney General sent Uber a letter asking for details of the hack and how the company responded. What's more, Uber appears to have broken a promise made in a Federal Trade Commission settlement not to mislead users about data privacy and security, a legal expert says... In addition to its agreement with the FTC, Uber is required to follow laws in New York and 47 other states that mandate companies to tell people when their drivers' license numbers are breached. Uber acknowledged Tuesday it had a legal requirement to disclose the breach."

The Financial Times reported that the U.K. Information Commissioner's Office is investigating the incident, along with the National Crime Agency and the National Cyber Security Centre. New data protection rules will go into effect in May, 2018 which will require companies to notify regulators within 72 hours of a cyber attack, or incur fines of up to 20 million Euro-dollars or 4 percent of annual global revenues.

Let's summarize the incident. It seems that a few months after settling a lawsuit about a data breach and its data security practices, the company had another data breach, paid the hackers to keep quiet about the breach and what they stole, and then allegedly chose not to tell affected users nor regulators about it, as required by prior settlement agreements, breach laws in most states, and breach laws in some international areas. Geez. What chutzpah!

What are your opinions of the incident? Can Uber and its executives be trusted?


Considerations For Consumers Affected By The Equifax Breach

Earlier this month, Discover sent me a replacement credit card. The letter with the replacement card stated:

"Notice of Data Breach
What happened: we recently learned your Discover card account might have been part of a data breach. Please know, this breach did not involve Discover card systems.
What we are doing to resolve: we are issuing you a new card with a new account number, security code, and expiration date to reduce the possibility of fraud on your account... So as a safety precaution, we are issuing you a new card to protect your Discover card account information from being misused"

Good. I like the proactive protection, and hope that the retailer absorbed the costs of replacement cards for all affected consumers like me. However, the letter from Discover didn't identify the retailer. I called Discover's customer service hotline. The phone representative wouldn't identify the retailer, either. I'd shopped at four retail stores during the past month, and assumed it was one of them. It wasn't.

Equifax logo On Saturday, I received via postal mail a breach notification letter from Equifax dated October 23, 2017:

"We are writing with regard to the cybersecurity incident Equifax announced on September 7, 2017. At Equifax, our priorities with regard to this incident are transparency and continuing to provide timely, reassuring support to every consumer. You are receiving this letter because the credit or debit card number used to pay for a freeze service, credit score, or disclosure of your Equifax credit file was accessed. We have no evidence that your credit file itself was accessed."

So, confirmation that it was Equifax's fault. What to make of this? Keep reading.

First, thanks Equifax for the postal mail notice. However, this isn't timely communication. Why? Equifax considers it's September 7th press release timely communication. How many consumers read Equifax press releases? Did you? My guess, most don't.

Thankfully, I read online newspapers and was aware of the breach soon after Equifax's September 7th announcement. Yet, my postal letter from Equifax arrived seven weeks after its September 7th press release (and almost three months after it first discovered the breach on July 29).  This incident is a reminder for consumers not to rely upon postal mail for breach notices. Many states' breach notice laws allow for companies to post public notices online in websites and/or in newspaper advertisements. This allows companies to skip (the expense of) mailing individual breach notices via postal mail.

The October 23rd Equifax breach letter also stated:

"On September 7, 2017, Equifax notified U.S. customers of the data security incident, including that 143 million U.S. consumers were impacted. On October 2, 2017, following the completion of the forensic portion of the investigation of the incident, Equifax announced that the review determined that approximately 2.5 million additional U.S. consumers were potentially impacted. Equifax also announced that credit card numbers for approximately 209,000 consumers and certain dispute documents, which included personal identifying information, for approximately 182, 000 consumers were accessed."

So, I am one of the "lucky" 209,000 consumers in the United States whose payment information was exposed stolen in addition to other sensitive personal information. Thanks Equifax for failing to protect my sensitive personal -- and payment -- information you are entrusted to protect.

Second, to upgrade earlier this year from slow, antiquated DSL to fiber broadband from Verizon, I used my credit card to pay for a temporary lift of the security freeze on my Equifax credit report. Why did Equifax retain my payment information for this transaction? Why did it retain that payment information in a complete and UN-encrypted format?

Discover's Frequently Asked Questions page for merchants advises merchants to do the following to protect consumers' highly sensitive payment card information:

"Tips for protecting customer information: a) Truncate all credit card information; b) Avoid storing CID data in your records or within sales data; c) Secure your site; d) Store data securely; e) Protect your data with firewalls; f) Limit authorized use and require passwords; g) Avoid storing customer or credit card information on your web server
Refer to your Merchant Operating Regulations for further card-not-present (CNP) requirements for the submission of sales."

So, it seems that Equifax failed to follow Discover's data security guidelines for merchants. (Browse privacy guidelines for merchants by other card issuers.) I do not have any ongoing services or subscriptions with Equifax, so there seems to be no need for it to retain my full credit card payment information. Not good. I called the Equifax customer service hotline. The phone representative could not explain why Equifax retained my payment information. Not good.

Third, Equifax failed to customize the letter for my situation. In 2008, I placed security freezes on my credit reports at Equifax, Experian, and TransUnion. So, Equifax already knows I have a security freeze in place, and failed to customize the letter accordingly. Rather than explain what applies to customers in my situation, instead the letter repeated the same general fraud-prevention advice for all consumers: how to contact the FTC, visit annualcreditreport.com for free copies of credit reports, file a police report if a victim of identity theft, place a fraud alert or security freeze on my credit reports for protections, and how to lift/remove an existing security freeze. Not good.

This was fast becoming a crappy customer experience.

Fourth, while on the phone with Equifax's customer service I asked if the TrustedID Premier credit monitoring service it ofered would work with the security freezes in place at all three credit reporting agencies. The phone representative said yes, but that the "credit file lock feature" would not work. What's that? According to the Equifax FAQ page:

"What is the difference between a credit file lock and a security freeze?
At their most basic level, both prevent new creditors from accessing your Equifax credit report, unless you give permission or take an action such as removing, unlocking or lifting the freeze or lock. Both a security freeze and a credit file lock help prevent a lender or other creditor from accessing a consumer’s credit report to open unauthorized new accounts.

  • Security freezes were created in the early 2000’s, are subject to regulation by each state and use a PIN based system for authentication.
  • Credit file locks were created more recently, are mobile-enabled and use modern authentication techniques, such as username and passwords and one-time passcodes for better user experience."

So, the "credit file lock" feature is new and different from a security freeze. The new feature allows mobile users to easily and quickly unlock/lock your Equifax credit reports. That seems beneficial for consumers needing frequent and quick access to credit. According to the FAQ page, the new feature will be "free, for life." The above description gives the impression that security freezes are antiquated.

To further understand this new feature, I visited the TrustedID Premier Privacy Policy page, which stated:

"The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and credit card information; Payment history and transaction history; Credit scores and credit history"

The "depend on the product or service you have" seems vague and broad. Just tell me! Plus, "transaction history" could include geo-location: where you bought something since some purchases are made at brick-and-mortar retail stores. It could also include when and where you use the "credit file lock" feature. So, even though the policy doesn't explicitly mention geo-location data collection, it seems wise to assume that it does. For the new "credit file lock" feature to work on your phone, it probably needs to know your location -- where you and your phone are.

So, this new feature seems to be a slick way for Equifax to collect (and archive) location data about when, where, the duration, and frequency of consumers' travels in the physical world -- something it couldn't get previously through the traditional security freeze process. Remember, any app on your smartphone can collect location data.

Plus, the "credit file lock" feature won't work with a security freeze in place. According to the customer service representative, consumers need to remove a security freeze for the credit file lock feature to work. This is a new, important wrinkle which consumers must understand in order to make informed decisions.

The representative said it would be free to remove the security freeze on my Equifax credit report in order to use the new feature. I asked if the TrustedID Premier service Equifax offers would work with credit reports from Innovis. The rep said no. The duration of my phone call was long since the representative needed to place me on hold and check with others in order to answer my questions. This did not instill confidence.

Plus, this lengthy question-and-answer page about Equifax's services indicates that many consumers (and perhaps some Equifax customer service representatives) don't fully understand the differences between security freezes, credit file locks, and other service features.

Fifth, the letter from Equifax did not mention any of the new threats nor the additional protection steps consumers must take, both of which you can read about in this October 10th blog post. Even though I've written about privacy, data breaches and credit monitor for the past 10+ years, like you there are new things to learn. It seems that Equifax is hoping that breach victims will take the easy route: enroll in TrustedID Premier -- which is free for now, but will likely cost you later.

Overall, for me it was a crappy post-breach customer experience with Equifax. I expected better -- better data security and a better post-breach support. Plenty of news articles have documented the security problems, failures, and post-breach problems with Equifax's breach site.

What are your opinions? What do you think of the new credit file lock feature? If you've used it, share your experience in the comments section below the image.

Overview of features. TrustedID Premier service. Click to view larger version