When completing the spreadsheet referenced within the Final PFI Report under Appendix C: Impacted Entities, an accountThe At-Risk Timeframe refers to the period of time data elements, such as account data, were at risk for this Entity Under Investigation during the incident under investigation. A data element is considered " at risk" if evidence indicates the account numberdata element was exposed (i.e. accessible toper the Final PFI Report template v3.3, Section 3.4 “a data element was accessible to the Entity under investigation or 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 breached entity were at riskas identified in the Final PFI Report template, Appendix C refers to the period of time during the incident under investigation when data was vulnerable. 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 2024-04-14T18:30:00 and was discovered by the breached entity (who subsequently took the system offline to limit the exposure) 2024-04-17T07:15:00.
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 breached entity had several years"' worth of account numbersdata elements stored in the environment;. In this case, regardless of how many data elements were exposed or how long they were stored, the " at-risk timeframe":
would not date back to the oldest account number stored, as the at-risk timeframedata element stored, and
only refers to the timeframe itself — the period of time the account numbersdata elements 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.
For additional information please contact your case-specific Payment Brand representative.
