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Data Breaches Preparedness – Practical Tips for
 Responding
                                         presented by Christine El Eris, Product Director, Affinion Group




Proprietary & Confidential   www.affinion.com
What is a Data Breach?




       A breach is defined as an event in which an individual name plus
       Social Security Number (SSN), driver’s license number, medical
       record or a financial record/credit/debit card is potentially put at
       risk – either in electronic or paper format.




 Presentation
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Data Breaches Occur Every Day
      Breaches are a daily news item




      Yet many organizations, their IT, data security and senior management teams still
      hope:
                               “It won’t happen to us.”

      No matter how secure your web sites or data networks are, it may just be a matter
      of time before
          – an employee loses a laptop containing critical data
          – a staffer clicks on a phishing link that launches malware or lets an attacker in to the
            company network
          – a third party supplier improperly handles your members’ data
          – a hacker takes advantage of a vulnerability in security weakness of a third party vendor
            or supplier


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Organizational Risks
      All Sectors Are Vulnerable
               Breached entities include Corporations, Healthcare, Government, Financial, Colleges &
               Universities
      Breaches Exposed More Data in 2011 than 2010
              According to the Identity Theft Resource Center, there were 662 breaches in 2010 identified as of
               12/29/2010 affecting over 16 million records
              2011 saw 414 reported incidents with nearly 23 million records impacted
              Complexities of the crime continue to change

      Legislative Environment Increasingly Complex
              Breach notification laws now in 46 states plus District of Columbia
              Federal Trade Commission’s Red Flag rules
              State AG expectations for post-breach response
              Specter of federal regulation in the future


      Increased Consumer Expectations
               Your members expect MORE than just a notification and credit monitoring when their personal data
               has been exposed



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Trends: Identity Theft
 Consumer Risks

    Consumers whose data has been exposed as the result of a data breach are
               four times more likely to become victims of identity fraud


    New account fraud has become significantly more complicated:
                It takes more than 140 days to be detected
                And requires more than 180 days to be resolved
                And consumers incur more than $1,200 of out-of-pocket expense




                Source: 2011 Javelin Strategy & Research “Identity Fraud Survey Report”


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How to Respond to a Data Breach Incident




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What NOT to Do … a Lesson from Sony




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Immediate First Steps
  • Assemble your response team
         – Who should be involved? How will you manage resources?


  • Conduct a risk assessment
         – Who is affected? Do you need to notify customers/clients/patients whose data was impacted?


  • Comply with federal and state regulations
         – How can you avoid fines? Will there be an investigation?
         – How can you prepare for inevitable lawsuits?
         – 46 states and the District of Columbia mandate notifications to impacted individuals (based on
           residency of breached individuals, not the organization who lost the data or where the data resided)
         – Become familiar with state AG opinions on notifying consumers and providing post-incident
           remediation services
         – Pay attention to FTC’s guidelines
         – Keep your attorney included in all discussions related to the incident to protect attorney-client privilege


  • Set up a call center
         – What resources are required? How will you serve non-English speakers if applicable?




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Utilize Experts As Needed
  • Implement a public relations/brand management strategy to manage and repair your
    corporate reputation

  • Consider a trusted third-party to manage the state-mandated notifications and provide post-
    incident identity protection and credit monitoring services

  • Consider a trusted third-party to conduct forensic analysis – even if you know what occurred,
    it is best to out-source this function

  • Employ outside counsel who are experts on data privacy law to assist your in-house counsel

  • Consider pre-contracting for each of the above services
         – Saves time when an event occurs
         – Enables your organization to properly perform due diligence on each partner in advance and at
           your own pace




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How Can Affinion Security Center Help?




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Affinion Security Center History

               Identity theft market leader                       Comprehensive solutions

                                        200                           15 million
           #1      provider of
                  identity theft
                                    configurations of
                                   benefits supported
                                                                      identities protected
                                                                                                FCRA- and MAGIC-
                                                                                              certified staff using well-
                    services                                                                    defined policies and
                                                                       5 years                     fraud resolution
                                          35+ years                average tenure of our
                                                                                                      procedures
       $25+ million                                                    caseworkers
        invested in product                                                                          15 years
      development, servicing
     and testing of benefits in
                                     Next Gen                         Siebel CRM                      average tenure
                                    solutions empowering          with automated workflow used       for team leaders
         the last year alone
                                    consumers to prevent,           for case management and
                                   detect and resolve fraud                  reporting


               Financially strong                                   The largest multi-channel reach
                                       Scalable platform to                                         True multi-channel
               $1.4 billion              accommodate                     18+ Million
               in 2010 revenue            future growth                  customers offered
                                                                                                         reach
                                                                                                    through direct mail,
                                                                         breach remediation
       Cited by Inc. Magazine as one of the                                                          in-branch, online,
                                                                              solutions
        fastest growing private companies                                                                telephony
                                                                    Marketing in
                                                                                                   More than
                                              24%                      16
       $164+ million                  increase in profitability
                                                                  countries around
                                                                                                 1 billion
           in cash at year-end         over the last 5 years                                     unique contacts
                                                                     the world
                                                                                                 made annually

Presentation
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Affinion’s Product Road Map – Identity Theft Solutions
Ability to Combat a Full-Spectrum of ID Fraud Issues


      Credit Monitoring with        Public Records               Evaluate ID Fraud Risks   Real time activity alerts;
         the 3 bureaus                                                                       credit & non-credit




   Credit Header, Proprietary     “Deputize the Consumer” by
           Databases              providing him or her meaningful,
                                  actionable alerts to evaluate if
                                                                                           Peer-to-Peer File Exchange
                                  fraud is occurring to stop it fast.                               Networks
                                            Concept coined by:



                                Internet Directories & Web            Social Media


    Black Market Web and                                                                    Children SSN Monitoring
   Underground Chat-Rooms




Presentation
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ASC’s End-to-End Solution
Service




                              Incident                                  Notification                              ID Theft                                       Ongoing
                                                                                             Customer                                   Enrollment
                             Response          List Services            Drafting &                               Protection                                     Support &
                                                                                              Support                                    Options
                             Consulting                                  Printing                                 Services                                      Reporting

                          Proactive          List hygiene            Drafting            Pre-enrollment       Prevention             Full File              Standard or
                          preparation                                                    breach FAQ                                  Enrollment             ‘a la carte’
Description




                                             De-duping               Printing            support              Detection                                     requests
                                                                                                                                     VRU/Call Center
                                             NCOA services           Mailing             Enrollment           Resolution
                                                                                         support              Services*              Online
                                             USPS compliance
                                                                                         Post-enrollment                             USPS
                                                                                         remediation


                                 Average timeline for all enrollment options being functional is 21 days from when ASC learns of a breach
The Affinion Difference




                          Established best   20 individuals          Highly scalable     Proven scale to      More than 15           Over 1 Billion         Breach team
                          practices          dedicated to            services to         support 40 million   million consumers      unique contacts        dedicated to
                          leveraging         limiting notification   support 700         calls annually       enrolled in ID theft   annually through       your account
                          experience from    costs                   million pieces of   across 20 call       protection today       multiple channels,     offering
                          hundreds of                                mail annually       centers                                     including              completely
                          breaches                                                                                                   dedicated VRU          customizable
                                                                                         Dedicated fraud                             enrollment             reporting at no
                                                                                         resolution                                                         additional
                                                                                         specialists                                                        charge
                                                                                         averaging 5 years
                                                                                         tenure per case
                                                                                         worker




   Presentation
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Case Study: Top 10 FI
                                    Impacted Population: 4.5 Million

     List Services
     After a major consulting and auditing firm hired to do 'forensics' on the 60+ impacted databases had
     already spent weeks working on record cleansing, BreachShield stepped in.

     Our team of database experts was able to scrub the files within 72 hours.

     Using our NCOA and de-duping capabilities, we reduced the mailing cost to 1/4 of the amount initially
     expected.

     Contact Center
     To ensure an optimal customer experience and preserve SLA levels while managing increased call center
     volumes, Affinion Security Center (ASC) utilized both VRU and live agent options.

     40% of callers opted for the VRU, minimizing the financial impact to the client.


     Positive results for the client:
     •     Notification process was expedited

     •         Proper list management and use of VRU saved the client over $1
               million

Presentation
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Case Study: Insurance Carrier
                                 Impacted Population: 500,000
   The Client Declined our Services
   Instead, the simply mailed notification letters to the impacted population.

   Facing increasing media and legal pressures, the client later offered a referral to an optional
   ID theft protection service on their website and via their contact center.

   Less than a year later, the client faced a class-action lawsuit. A major settlement component
   was offering two years of ID theft protection service to the impacted population, with costs
   that were much greater than Affinion Security Center’s initial price quote.


   A proactive and thorough response plan would have:
   1)   Protected their brand from negative PR

   2)          Significantly reduced costs

   3)          Provided a robust solution to the affected population



Presentation
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Case Study: Entertainment Company

                              Impacted Population: 50 Million

   Flexibility to Meet Diverse Needs
   An entertainment company has a breach that affected more than 50 million individual
   customers. While the company was pre-contracted within the US with another provider, they
   found that provider inadequate for international needs.

   Starting from scratch, Affinion Security Center was able to create a solution for 10
   million impacted users in less than 30 days.




                           Positive Result for the Client:
                 Media scrutiny was significantly lessened overseas.




Presentation
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A Trusted Resource




                                 This publication includes:

                             • Data breach facts and terms

                             • Explanations of breach
                               notification laws

                             • Suggested incident response
                               action plan

                             • Sample customer notifications




               www.nafcu.org/affinion
Presentation
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        For

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Data Breaches Preparedness (Credit Union Conference Session)

  • 1. Data Breaches Preparedness – Practical Tips for Responding presented by Christine El Eris, Product Director, Affinion Group Proprietary & Confidential www.affinion.com
  • 2. What is a Data Breach? A breach is defined as an event in which an individual name plus Social Security Number (SSN), driver’s license number, medical record or a financial record/credit/debit card is potentially put at risk – either in electronic or paper format. Presentation Prepared www.affinion.com 2 For
  • 3. Data Breaches Occur Every Day Breaches are a daily news item Yet many organizations, their IT, data security and senior management teams still hope: “It won’t happen to us.” No matter how secure your web sites or data networks are, it may just be a matter of time before – an employee loses a laptop containing critical data – a staffer clicks on a phishing link that launches malware or lets an attacker in to the company network – a third party supplier improperly handles your members’ data – a hacker takes advantage of a vulnerability in security weakness of a third party vendor or supplier Presentation Prepared www.affinion.com 3 For
  • 4. Organizational Risks All Sectors Are Vulnerable Breached entities include Corporations, Healthcare, Government, Financial, Colleges & Universities Breaches Exposed More Data in 2011 than 2010  According to the Identity Theft Resource Center, there were 662 breaches in 2010 identified as of 12/29/2010 affecting over 16 million records  2011 saw 414 reported incidents with nearly 23 million records impacted  Complexities of the crime continue to change Legislative Environment Increasingly Complex  Breach notification laws now in 46 states plus District of Columbia  Federal Trade Commission’s Red Flag rules  State AG expectations for post-breach response  Specter of federal regulation in the future Increased Consumer Expectations Your members expect MORE than just a notification and credit monitoring when their personal data has been exposed Presentation Prepared www.affinion.com 4 For
  • 5. Trends: Identity Theft Consumer Risks  Consumers whose data has been exposed as the result of a data breach are four times more likely to become victims of identity fraud  New account fraud has become significantly more complicated:  It takes more than 140 days to be detected  And requires more than 180 days to be resolved  And consumers incur more than $1,200 of out-of-pocket expense Source: 2011 Javelin Strategy & Research “Identity Fraud Survey Report” Presentation Prepared www.affinion.com 5 For
  • 6. How to Respond to a Data Breach Incident Presentation Prepared www.affinion.com 6 For
  • 7. What NOT to Do … a Lesson from Sony Presentation Prepared www.affinion.com 7 For
  • 8. Immediate First Steps • Assemble your response team – Who should be involved? How will you manage resources? • Conduct a risk assessment – Who is affected? Do you need to notify customers/clients/patients whose data was impacted? • Comply with federal and state regulations – How can you avoid fines? Will there be an investigation? – How can you prepare for inevitable lawsuits? – 46 states and the District of Columbia mandate notifications to impacted individuals (based on residency of breached individuals, not the organization who lost the data or where the data resided) – Become familiar with state AG opinions on notifying consumers and providing post-incident remediation services – Pay attention to FTC’s guidelines – Keep your attorney included in all discussions related to the incident to protect attorney-client privilege • Set up a call center – What resources are required? How will you serve non-English speakers if applicable? Presentation Prepared www.affinion.com 8 For
  • 9. Utilize Experts As Needed • Implement a public relations/brand management strategy to manage and repair your corporate reputation • Consider a trusted third-party to manage the state-mandated notifications and provide post- incident identity protection and credit monitoring services • Consider a trusted third-party to conduct forensic analysis – even if you know what occurred, it is best to out-source this function • Employ outside counsel who are experts on data privacy law to assist your in-house counsel • Consider pre-contracting for each of the above services – Saves time when an event occurs – Enables your organization to properly perform due diligence on each partner in advance and at your own pace Presentation Prepared www.affinion.com 9 For
  • 10. How Can Affinion Security Center Help? Presentation Prepared www.affinion.com 10 For
  • 11. Affinion Security Center History Identity theft market leader Comprehensive solutions 200 15 million #1 provider of identity theft configurations of benefits supported identities protected FCRA- and MAGIC- certified staff using well- services defined policies and 5 years fraud resolution 35+ years average tenure of our procedures $25+ million caseworkers invested in product 15 years development, servicing and testing of benefits in Next Gen Siebel CRM average tenure solutions empowering with automated workflow used for team leaders the last year alone consumers to prevent, for case management and detect and resolve fraud reporting Financially strong The largest multi-channel reach Scalable platform to True multi-channel $1.4 billion accommodate 18+ Million in 2010 revenue future growth customers offered reach through direct mail, breach remediation Cited by Inc. Magazine as one of the in-branch, online, solutions fastest growing private companies telephony Marketing in More than 24% 16 $164+ million increase in profitability countries around 1 billion in cash at year-end over the last 5 years unique contacts the world made annually Presentation Prepared www.affinion.com 11 For
  • 12. Affinion’s Product Road Map – Identity Theft Solutions Ability to Combat a Full-Spectrum of ID Fraud Issues Credit Monitoring with Public Records Evaluate ID Fraud Risks Real time activity alerts; the 3 bureaus credit & non-credit Credit Header, Proprietary “Deputize the Consumer” by Databases providing him or her meaningful, actionable alerts to evaluate if Peer-to-Peer File Exchange fraud is occurring to stop it fast. Networks Concept coined by: Internet Directories & Web Social Media Black Market Web and Children SSN Monitoring Underground Chat-Rooms Presentation Prepared www.affinion.com 12 For
  • 13. ASC’s End-to-End Solution Service Incident Notification ID Theft Ongoing Customer Enrollment Response List Services Drafting & Protection Support & Support Options Consulting Printing Services Reporting Proactive List hygiene Drafting Pre-enrollment Prevention Full File Standard or preparation breach FAQ Enrollment ‘a la carte’ Description De-duping Printing support Detection requests VRU/Call Center NCOA services Mailing Enrollment Resolution support Services* Online USPS compliance Post-enrollment USPS remediation Average timeline for all enrollment options being functional is 21 days from when ASC learns of a breach The Affinion Difference Established best 20 individuals Highly scalable Proven scale to More than 15 Over 1 Billion Breach team practices dedicated to services to support 40 million million consumers unique contacts dedicated to leveraging limiting notification support 700 calls annually enrolled in ID theft annually through your account experience from costs million pieces of across 20 call protection today multiple channels, offering hundreds of mail annually centers including completely breaches dedicated VRU customizable Dedicated fraud enrollment reporting at no resolution additional specialists charge averaging 5 years tenure per case worker Presentation Prepared www.affinion.com 13 For
  • 14. Case Study: Top 10 FI Impacted Population: 4.5 Million List Services After a major consulting and auditing firm hired to do 'forensics' on the 60+ impacted databases had already spent weeks working on record cleansing, BreachShield stepped in. Our team of database experts was able to scrub the files within 72 hours. Using our NCOA and de-duping capabilities, we reduced the mailing cost to 1/4 of the amount initially expected. Contact Center To ensure an optimal customer experience and preserve SLA levels while managing increased call center volumes, Affinion Security Center (ASC) utilized both VRU and live agent options. 40% of callers opted for the VRU, minimizing the financial impact to the client. Positive results for the client: • Notification process was expedited • Proper list management and use of VRU saved the client over $1 million Presentation Prepared www.affinion.com 14 For
  • 15. Case Study: Insurance Carrier Impacted Population: 500,000 The Client Declined our Services Instead, the simply mailed notification letters to the impacted population. Facing increasing media and legal pressures, the client later offered a referral to an optional ID theft protection service on their website and via their contact center. Less than a year later, the client faced a class-action lawsuit. A major settlement component was offering two years of ID theft protection service to the impacted population, with costs that were much greater than Affinion Security Center’s initial price quote. A proactive and thorough response plan would have: 1) Protected their brand from negative PR 2) Significantly reduced costs 3) Provided a robust solution to the affected population Presentation Prepared www.affinion.com 15 For
  • 16. Case Study: Entertainment Company Impacted Population: 50 Million Flexibility to Meet Diverse Needs An entertainment company has a breach that affected more than 50 million individual customers. While the company was pre-contracted within the US with another provider, they found that provider inadequate for international needs. Starting from scratch, Affinion Security Center was able to create a solution for 10 million impacted users in less than 30 days. Positive Result for the Client: Media scrutiny was significantly lessened overseas. Presentation Prepared www.affinion.com 16 For
  • 17. A Trusted Resource This publication includes: • Data breach facts and terms • Explanations of breach notification laws • Suggested incident response action plan • Sample customer notifications www.nafcu.org/affinion Presentation Prepared www.affinion.com 17 For