Frequently Asked Question

What is meant by ‘at risk’ and ‘at-risk timeframe’ referenced in the Final PFI Report?

When completing the spreadsheet referenced within the Final PFI Report under Appendix C: Impacted Entities, an account is considered “at risk” if evidence indicates the account number was exposed (i.e. accessible to any unauthorized entity, process, source, etc.) during the incident under investigation. The “At-Risk Timeframe” refers to the period of time the account numbers for this merchant were at risk during the incident under investigation.

For example, consider a scenario where evidence (e.g., system/access logs) indicates that an unauthorized entity breached the cardholder data environment’s security controls on 2017-04-14T18:30:00 and was discovered by the merchant (who subsequently took the system offline to limit the exposure) 2017-04-17T07:15:00. The at-risk timeframe is considered to have been from 6:30PM on April 14th when the breach occurred, through 7:15AM on April 17th when the breached system was taken offline (approximately 60 hours).

Further considering the scenario above, suppose the merchant had several years’ worth of account numbers stored in the environment; the “at-risk timeframe” would not date back to the oldest account number stored, as the at-risk timeframe only refers to the timeframe itself – the period of time the account numbers were at risk (approximately 60 hours in this scenario) – regardless of how many numbers were exposed or how long they were stored.  Details about the data exposed/at risk are covered under section 3.4 of the report, where the PFI describes the possible exposure, the volume of cards at risk, etc. for the affected Payment Brands.

April 2017
Article Number: 1448