Forever 21: Assessor Missed 5-Year-Old Transaction Data

Written by Evan Schuman
October 1st, 2008

As more details drip out from Forever 21’s data breach of almost 100,000 payment cards, the chain now says it had been certified PCI compliant, despite having stored complete card information from as far back as 2003.

"The files were inadvertently retained within other data files and this was not uncovered by the assessor," a statement from the chain said. (Our story from last week has been updated with the new information, along with a link to the earlier report of the breach.)

This is proving to be a frightening trend, with retailers believing they are compliant and much later on discovering various pockets of forbidden data scattered through their network.

In Forever 21’s case, it only learned of the breach when the U.S. Secret Service called. Even after that heads up, the chain said it was unable to verify that it had been breached until the Secret Service walked executives through the incident and gave them more information (months later).

One of the problems in this case—and it could be argued it’s a problem with PCI itself—is that it’s up to the retailer’s IT person to map out the networks for the assessor. If the IT manager isn’t aware that someone from marketing had run a credit card experiment two years ago and that the files were never deleted (meaning that there might be live credit card data sitting in a marketing folder that IT would have no reason to ever look at), then IT can’t tell that to the assessor.

In other words, the assessor has almost no chance of finding that data, making the certification much less meaningful.


5 Comments | Read Forever 21: Assessor Missed 5-Year-Old Transaction Data

  1. Branden Williams Says:

    QSAs with little experience and rock bottom pricing seem to have a catch; they don’t find everything they are supposed to. Regardless, I think merchants believe that it is the sole responsibility of the assessor to find all gaps, and anything that is not found by a QSA is exempt from liability. I doubt someone intentionally hid the data from assessors, but if you treat them like auditors, there is no question that things will get missed.

  2. Steve Sommers Says:

    I have a different take on this topic. Years back the banks used to send out cards with 2-4 year expiration dates. Now the banks cut costs by sending out cards with 4-12 year expiration at the expense of security. I’m sorry, banks make enough money on cardholders and merchants to send out replacement cards every four years. I place the entire blame for this particular case on the card brands for allowing the data to be valid for longer than 4 years.

  3. Steve Sommers Says:

    Also regarding “QSAs with little experience and rock bottom pricing,” the amount you pay does not directly relate to the quality of the assessment. I’ve seen “cheap guys” catch stuff the “premium guys” missed and visa-versa. I’ve never heard that Hannaford used the cheapest guy on the block yet a significant hole was never noticed.

  4. Bob Rich Says:

    “QSAs with little experience and rock bottom pricing seem to have a catch; they don’t find everything they are supposed to.” There isn’t enough information in this article to support that statement. Experience certainly plays a role, but price has nothing to do with it. In this case, the focus is on the presence of a file or files that i doubt _any_ QSA would have found (how many QSAs scan every drive in the enterprise). The question is how access to that file was obtained, and if it was a lack of compliance that allowed that to happen.

  5. Harlow Says:

    Forever 21 should go out of business not Ciruct City.


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