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Heartland Data Breach Analysis


Abstract and Figures

Around 2008 an US company, called Heartland, suffered from a massive data breach, which resulted to be biggest leak of cardholder data until that time. This report briefly recall, by citing official sources and newspapers, the most important event happened both before and after the attack with the aim of describing later which weaknesses affected the company at the time. Since Heartland relied only on PCI-DSS compliance, a description of main security controls that were not present is provided and subsequently two cyber-security framework (NIST and CIS) are applied to the case in order to understand if they could have mitigated some of the main consequences to highlight the importance of implement such standards as a preemptive defense to concrete cyber attacks. At the end a summary section compares advantages and drawback, derived from their practical application, of both frameworks.
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H D B A
Cingolani Alessandro
Master Degree in Cybersecurity
Sapienza University of Rome
Zamparini Matteo
Master Degree in Cybersecurity
Sapienza University of Rome
February 13, 2020
Around 2008 an US company, called Heartland, suffered from a massive data breach, which
resulted to be biggest leak of cardholder data until that time. This report briefly recall, by
citing official sources and newspapers, the most important event happened both before
and after the attack with the aim of describing later which weaknesses affected the company
at the time. Since Heartland relied only on PCI-DSS compliance, a description of main
security controls that were not present is provided and subsequently two cyber-security
framework (NIST and CIS) are applied to the case in order to understand if they could
have mitigated some of the main consequences to highlight the importance of implement
such standards as a preemptive defense to concrete cyber attacks. At the end a summary
section compares advantages and drawback, derived from their practical application, of
both frameworks.
1 Introduction
Figure 1: Taken from the Nilson
On January 20 2008 Heartland Payment System, a US-based payment
processing and technology provider, announces publicly, on the same
day of the President Obama’s inauguration, that it had suffered a devas-
tating security breach within its processing system.
At the time of the misdeed Heartland processed 100 million payment
card transactions per month which lead this attack to be considered the
biggest data breach ever occurred (until that moment).
The company both before and in the course of the breach was in com-
pliance with the Payment Card Industry Data Security Standard (PCI
], required by credit card providers such as Visa and Mastercard
in order to be approved to process their card’s payments.
The hackers managed to enter inside the company’s system by exploiting
an SQL injection present in an eight years old web login page, subse-
quently, they spent 8 months attempting to access the payment process-
ing network while trying to avoid detection from the several different
anti-virus systems used by Heartland.
After hackers exploited the web-login page vulnerability Heartland con-
ducted several security audits engaging third-party companies all of
which have confirmed that it was PCI compliant. Notwithstanding
Visa first alerted Heartland about "suspicious activity surrounding cer-
tain cardholder accounts" nearly one year later and this lead the com-
pany to call U.S. Secret Service and hire two breach forensic teams to
]. A malicious software, that apparently allowed the hackers
to stole the data, was discovered.
The company specified that no merchant data, cardholder Social Security numbers (SSN), unencrypted
personal identification numbers (PIN), addresses or telephone numbers were jeopardized as a result of the
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breach; however, the stolen data includes the digital information written into the magnetic stripe present
on credit and debit cards. Equipped with this information, criminals can design counterfeit credit cards by
imprinting the same stolen data on manufactured cards. Although this can seems quite useless, according
to the Nilson Report[
] those kinds of thefts was a very profitable business at the time which caused 7.6
Billions of dollars losses globally only in 2010 [Fig. 1].
On the other hand, in terms of revenue, Heartland reportedly had to pay around $145 million in compen-
sation for fraudulent payments, according to Judge. The figure includes a fine of nearly $60 million from
Visa, another of about $3.5 million with "American Express" along with approximately $26 million in legal
After the breach the CSO Jonh South has focused his efforts on staying ahead of future breaches, employing
security technology to do so and working to increase communication with industry colleagues.
Figure 2: Heartland stock price, analysis, 9/1/2009-30/1/2009, (source:
2 Company Security Policies and Status
One interesting aspect of that breach is that Heartland were aware of the potential security threats that
could target those companies that process payments and consequently at the time various security policies
were put in place.
By examining the 2008 company’s "Form 10-K"[
], a required annual report that gives to stakeholders
an overview of company’s financial performance, company state that "We place significant emphasis on
maintaining a high level of security in order to protect the information of our merchants and their customers.".
This sentence is then justified in accordance with the applied security policies since the report remarks that
they maintained current updates of networks, operating system security releases and virus definitions in
conjunction with third-party regularly test that aimed to detect systems for vulnerability to unauthorized
access. Furthermore sensitive data stored inside databases (like cardholder numbers) were protected with
tripe-DES encryption which represented the highest commercially available standard for encryption.
The company also have emphasized their certifications pointing out that they successfully applied the
Payment Card Initiative Data Security Standard (PCI-DSS) which reviewed Heartland’s payment processing
and Internet-based reporting systems.
Along with that they also implemented an annual "SAS-70" review engaging external auditors and pub-
lishing the Report on Controls Placed in Operation and Tests of Operating Effectiveness" and meanwhile is
mentioned that they undertook an independent Cyber-Risk Assessment.
On the same document, specifically in the "Risk Factor" section, Heartland explicitly presents the possibility
of "Unauthorized disclosure of merchant and cardholder data through breach of our computer systems"
consciously explaining the related consequences of this event, such as sanctions by Visa and MasterCard.
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Figure 3: Paragraph of the Form 10K where Heartland precisely describe what the consequences of a data
breach will be. (Page 30)
3 The Data Breach
This section contains a detailed technical analysis of the event occurred during the attack, specifying which
was the vulnerabilities and how they were exploited. The majority of the reported information comes from
the FBI advisory[
] released after the three important breaches happened between 2007 and 2008
although the advisory was not specific for the Heartland, there are plenty of reasons to believe that the
example attack presented in the document is very similar to the one used in this case study.
The breach was a very slow moving event. It started in 2007 when the hackers exploited, for the first time in
the company history, a SQL injection in a web login page which was developed eight years before[16].
Figure 4: Introduction of the FBI Advisory[7]
They used an extended procedure called
, which is installed by default on Microsoft SQL
Server (MSSQL), to download their hacker tools inside the compromised server. With this method, an
attacker is able to execute any command in the server with the same permissions of the user that is currently
running the database software. The most believable version of Microsoft SQL Server running in Heartland’
system at the time is "2000". Major hints come from the fact that the web site had been developed eight-year
before and the “xp_cmdshell” feature was disabled by default in version "2005". In addition on the "2000"
version, this procedure is only available if the database software runs with sysadmin rights which makes
the attackers able to perform a lot of more harmful actions.
During this period hackers were confined into the company’s corporate network, which, as required by
PCI-DSS policies, is separate from the process-payment system.
1In detail the Heartland, 7-Eleven Inc., Hannaford Brothers Co.[13]
Official documentation :
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Although at the time when the breach was announced (May 2008) Heartland knew how the corporate net-
work had been exploited, it was unaware the hackers were still present on its system for months conducting
reconnaissance. As a matter of fact, on April 30, Heartland hired Trustwave, a computer security firm, that
conducted an audit and deemed it compliant with PCI DSS.
After many investigations led by U.S. Secret Services and by two breach forensics teams[
] it was found
that the hackers have moved from corporate to process-payment network with the help of valid Windows
credential obtained using tools like
or similar. Such tools have been employed to extract NTLM
password hashes from Windows Security Account Manager(SAM). In details, NTML is a suite of Microsoft
security protocols intended to provide authentication, integrity, and confidentiality to users. Hackers had
probably cracked hashes due to the usage of weak passwords inside the company.
When they were inside the process-payment network hackers installed what is called a
"network sniffers"
which are able to catch any packet that passes through the network, including card data and all the systems
transaction. Sniffers are typically not identified by network security tools due to the fact that they are passive
auditors and therefore do not execute any particular action that could reveal their presence.
Subsequently the attackers managed to install back-doors able to communicate periodically with their
servers in order to secretly and persistently gain access to the compromised network.
Once they obtained regular access to the system hackers start to target Hardware Security Modules (
which are physical computing devices that safeguards and manages digital keys for authentication and
provides cryptoprocessing. They trying to attack applications and brute-force HSMs in order to obtain
some credit card data. To conclude the stolen data were transferred to a server owned by the attacker, which
in the end captured card account numbers, expiration dates and, in 20 percent of cases, the customer’s
name as well[2].
Figure 5: Court Sentence[13] where hackers moves are describer
3Official website:
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3.1 Timeline
2006 Heartland created the "Merchant Bill of Rights" which the company describes as "an
industry standard for fairness, honesty and transparency in credit and debit card
2007 Asecurity assurance was stipulated before the data breach occurred. Heartland made the
following affirmative representations concerning its security measures: "Our internal
network configuration provides multiple layers of security to isolate our databases from
unauthorized access and implements detailed security rules to limit access to all critical
December 2007 Attackers exploited a vulnerability and gain access to the network, although they were
confined into the company’s corporate network.[2]
Heartland caught the breach of the corporate network, but was unaware the hackers were
sitting on its system for months conducting reconnaissance.[2]
30 April 2008 Trustwave conduct an audit of Heartland and say it was compliant with PCI. [2]
May 2008 The hackers had jumped to the processing network[2]
October 2008 Visa first alerted Heartland about "suspicious activities surrounding certain cardholder
accounts" - nearly one year later the attack
November 4, 2008
Carr’s comments confirm that the PCI standards are minimal, and that the actual industry
standard for security is much higher, complaint says.
Heartland called U.S. Secret Service and hired two breach forensics teams to investigate. [
January 12, 2009 Investigation led to the discovery of "suspicious files".
January 13, 2009 Heartland uncovered "malicious software that apparently had created those files."
January 20, 2009 Heartland’s public disclosure, President Obama’s inauguration day.
March 14, 2009 Visa removed Heartland from its published list of PCI-DSS compliant service providers.
March 19, 2009 Speech at the Global Security Summit hosted by Visa in Washington D.C, said that the
Heartland data breach would not have occurred had the company had been vigilant about
maintaining its PCI compliance.
April 2009 Heartland was re-certified as PCI compliant by an auditor.
August 4 2009 Carr stated that the company’s end-to-end encryption project will offer merchants "the
highest level of beta security in the marketplace. [6]
June 2012 The attackers were arrested in Sweden.
2015 Both attacker were extradited in the USA.
4 Risks and control weaknesses identified
During out analysis we have tried to retrieve all possible document, spacing from technical[
] to business
]. After a careful analysis we started to make hypothesis about what went wrong at the time, how
and who is/are the main responsible(s) of this event.
At the beginning, before reading the entire reportage, we were sure that only problem was the initial SQL
injection vulnerability present in the old web page. However by carefully following the time-line is clear that
employees would had enough time (about 5 months) to spot unusual network activity also by considering
that the attackers had tried, for the entire period, to access the payment’s network (probably with many
attempts). In addition when they have detected the breach in the corporate network the attacker already
had gained access to the payment’s network.
It is obvious that something beyond the login page vulnerability have simplified the attackers work making
their criminal plan to succeeded.
In this section we have tried to identify and aggregate major weakness and errors that could have prevented
the data breach. Although a lot of disparate action might have blocked the attacker plan, we have selected
and grouped the major problems that affected the company before and during the attack.
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Lack of vulnerability check
: As described in the previous section, the attack started from a SQL injec-
tion, which still nowadays represent one of the most famous and exploited. Although the web login
page targeted by the hackers was probably developed around 2001, at that time SQL injection was
already well known to the world, so a process-payment company such as Heartland could not
disregard it.
By considering the size of the company, it would have been quite useful to use automated vulnera-
bilities scanning tools that could aware Heartland of code mistakes made on networks, web pages
and all others software developed years before; because a serious policy should pay particular
attention to old systems because is a well known fact that most of the cyber attacks start from the
weakest part of the chain.
In addition to automated tools would have been useful also hire some specialized auditor or pene-
tration test teams to check weaknesses of company’s system developed in the past, that probably
were underestimated by Heartland as an access point for cyber attacks.
Focusing on those weaknesses it is right to consider also the lack of a proper error checking mecha-
nism. As a matter of fact during the entire attack many actions conducted by the hackers should
have generated a large number of error messages, therefore it is quite impossible (as is written
below in the logging system weakness paragraph) that no alarm was triggered when they tried to
break the web page and the boundary of process-payment network.
A working approach to mitigate this weakness that could be helpful consists of better training for
the entire IT team. In fact to prevent this kind of code mistakes employees must be trained to use
secure protocols, mechanisms, procedures and templates which are already widely tested and
Network Monitoring
: Company clearly specified in the "Network Security" section of 2008’s Form 10K
that "Our internal network configuration provides multiple layers of security to isolate our databases
from unauthorized access and implements detailed security rules to limit access to all critical sys-
tems". At first glance, this policy is reflected in the company’s network separation between internal
and payment processing networks. This makes attackers work more complicated because they
need to overcome network boundaries in order to access critical services. In the end, this separation
was very effective since hackers spent about five months trying to bypass defenses and avoiding
anti-virus detection until they finally jumped into the processing network.
While solution worked as intended network segmentation should not be used alone but supported
with Intrusion Detection System (IDS) and strong firewall policies. Official documents do not ex-
plain how the attacker managed to break the security functionality, but the only useful information
for this analysis is that company became aware that someone was able to access the network only
on 13 November of 2009, approximately two years from the first time the web login vulnerability
was exploited. By putting aside the malfunctioning logging process the main problem here was the
fact that any of the present security software was able (or was not configured) to generate an alert
to the network admin.
Although the attackers studied various method to avoid detection, during the entire period when
they were present in the network they used a backdoor that "beacon" periodically to their command
and control servers (C&C), allowing easy access to the compromised networks. While the sniffer
software was passive and therefore nearly impossible to spot with network monitor tool, unusual
traffic either directed to the network boundaries or to the C&C external server should have been
spotted by network security solutions.
Consequently, since the company specified that they regularly performed software and anti-virus
definition updates[
] probably the network monitor software was inadequate or was not configured
properly to alert the security responsible.
To conclude even though is extremely difficult to create an impenetrable boundary, possible attack
can be immediately detected with the appropriate tool and then countermeasures could be taken.
Weak Password Policy
: Weak passwords are probably the major responsible of company breaches and
therefore are a curse in computer security. Even the most impenetrable company may be in danger
if one of their employees use an easily guessable password. In fact, a weak password leaves an open
door to the internal network, making the boundaries protection useless.
In this case study, FBI Advisory [
] declared that "Hackers obtained valid Windows credentials by
using fgdump or a similar tool". As stated in the previous section they extracted NTML hashes and
started to crack them in order to obtain some valid credentials. Since hashes are designed to be
impossible to invert (in other words discover the password), cracking a single one would require an
unsustainable amount of time. The only applicable option is to build up a dictionary containing
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the most common password and try each of them.
As a result only what is considered n the previous section they extracted NTML hashes and started to
crack them in order to obtain some valid credentials. Since hashes are designed to be impossible to
invert (in other words discover the password), cracking a single one would require an unsustainable
amount of time. The only applicable option is to build up a dictionary containing the most common
password and try each of them. As a result only what is considered "weak passwords" can be cracked
in short time. Obviously since the attackers managed to obtain credentials, probably at the time
Heartland did not enforce a comprehensive password policy.
One of the simple countermeasure to this phenomena consists in maintaining a blacklist of most
common password, like the one drafted by the National Cyber Security Centre (NCSC)
, in order
to avoid their usage. Even though blacklist seems effective, they are not a reliable solution. For
example, a secretary may use their child, pet name or a combination of them, which is very likely to
not be present in the list but anyway is simply guessable with a bit of social engineering. Therefore
one of the main weapons against password guessing is employees training. Only when they gain
awareness of the importance of password as a security mechanism effective policies can be applied,
otherwise, nobody is going to follow them.
Inadequate company services and infrastructures awareness
: This section slightly differs from the
"Lack of vulnerability check" (4), while the latter is related to security scans and audits of software
this one focuses on code review and on system patches and maintenance processes. PCI-DSS
compliance extensively cover the recommended guidelines for software security in requirement
number 6, under the name "Develop and maintain secure systems and applications"[10].
According to what is written in the introduction is likely to believe that Heartland ran a "Microsoft
SQL Server 2000" at the time. It is known that this version allows the execution of "xp_cmdshell"
only if the server runs with administrative privilege. Point 6.2 of PCI states that all software should
install all vendor security update within one month. Despite newer version of SQL Server were
released by Microsoft (2003, 2005, 2008) no critical CVE was present
on that version before the July
of 2008 which is in accordance with the audit performed by Trustwave in April.
Moreover the PCI documents only refer to the "least-privilege" principles only in human terms
and exclusively when cardholder data are involved
, which justifies why the auditors did not warn
about the fact that the database software runs with administrative privilege.
On the other hand, when looking at the web-login page, the PCI clearly states on the point 6.6 that
"For public-facing web applications, ... reviewing applications via manual or automated application
vulnerability security assessment tools or methods, at least annually, ... Installing an automated
technical solution that detects and prevents web-based attacks". In this case, the policy was not
applied since a simple review would have spotted the lack of sanitation on user input and migrated
to a modern solution (like SQL prepared statements). Furthermore (from what is publicly available)
no sort of "web application firewall" (WAF) was present at the time. Such software is great to filter
dangerous user input and can also be configured to alert the system administrator if suspicious
activity occurs.
To conclude, while the choice of maintaining an old (but still supported) software may be compre-
hensible, whereas the absence of a periodic software review and the lack of a WAF significantly
facilitate the attacker works.
Absence of a reliable and complete logging system and log-review process
: Logging systems are a
key component of the company infrastructure since they provide a comprehensive description
of events that occurred and therefore may help to troubleshoot. In addition, an exhaustive log
file can be used for various activities, in particular for security incident response and forensics,
so presumably, at the time Heartland’s logs were not so well-designed since employees were not
capable of understanding how the attackers got into the network until an external forensic team
was engaged.
The PCI-DSS standard includes a logging policy in the "Requirement 10"[
] which instruct about
what information must be logged, where logs should be stored and even requires a regular log
review process executed either by personnel or automated. In particular for each event related to a
system component "user identification, type of event, date and time, success or failure indication,
4NCSC Common password report:
6Requirements 7: "Restrict access to cardholder data by business need to know"
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origination of event, and identity or name of affected data, system component or resource"[
] have
to be stored.
During the entire period of the attack when the hackers worked undisturbed inside the company
infrastructure a security team with a PCI-compliant log should have been capable of noticing some
strange events in the periodic log review process.
It is not clear why despite Heartland was PCI compliant nobody inside the company realized what it
was happening. One possible explanation is that the work was left to an automated process which
failed to detect the breach.
However, the seriousness of the situation concerns the company event response. While the hackers
managed to jump into the processing network, Heartland finally discovered the breach of the
corporate network but "was unaware the hackers were sitting on its system for months conducting
]. employees were not able to spot the thieves presence even though by the net-
work activity log should contain some evidence. Since no further investigation was performed, the
attackers jumped into the processing network and, only after VISA alerted (one year after the initial
attack) about some "suspicious activity" the company finally managed to engage two forensics
If some sort of logging review process were performed periodically at the time, probably unusual
activities, like the ones generated by the malicious software or in general by the two hackers, would
have been discovered and some action might have been taken in place (like temporarily suspend
payments until a complete audit).
Lack of encryption on sensitive data
: Inside the Form 10K, the company explicitly stated that "card-
holder numbers that are stored in our databases are encrypted using triple-DES protocols" and
in this sense the company made a valid choice considering that at the time the used cipher was
the highest commercially available standard for encryption. This policy definitely prevented the
attacker from exfiltrating more sensitive data that could have caused a serious data breach that the
one happened.
The company has correctly applied the "encryption at rest" however for some reason they forgot
to protect some important data that used to transit in the payment processing network. After the
attackers have studied packets dump generated by the sniffer they discovered that digital informa-
tion encoded onto the magnetic present on the backs of credit and debit cards transited in clear
With such data, criminals can forge counterfeit credit cards by simply impressing on them the
stolen information. Nowadays the technology of credit card makes difficult to forge a valid card
with those information[
], but at the time the illegal market of counterfeit cards was very profitable,
according to the Nilson Report[
] worldwide losses from card fraud was about $8 billion in 2010. So
the problem to highlight here is the lack of "encryption in transit". It is not possible to say without
knowing the company’s infrastructure if other sensitive information transit through the network
protected with encryption, therefore is difficult to determine if the policy is only focused on data at
rest. By examining the PCI guidelines (6) it is possible to see that data like the one inserted into
the magnetic stripes and customers PIN cannot be stored anywhere for security reason. Though
since no PINs code were stolen this means that they probably travel on another network or was just
encrypted. Definitively the only indisputable statement is that the company failed to enforce their
sensitive information policy, allowing unencrypted flow of critical data across the internal network.
In our opinion, a simple inventory of the company data flow (like what information applications ex-
change) would have been enough to spot the implementation weakness. Others action like external
audit was not sufficient because of the amount of network traffic data that expert had (probably)
analyzed. In this sense even a powerful network logging software which is able to. determine if
sensitive data transit might spot the issue, but this solution is probably more expensive than having
a clear and complete data flow report.
Absence of an explicit and clear cyber security policy
: It is almost clear that Heartland, although were
PCI-DSS compliant and inside Form 10K claimed that they carried out an annual SAS-70 review,
they did not have a specific and complete Cyber Security policy.
This clearly was the main problem that lead the company to such impressive breach. All of the
weaknesses described above are just pixels of a big picture that form a more complete policy able
to detect, protect, prevent and mitigate the damage produced by the breach.
Having a Cyber Security policy means that Heartland had to check its networks, encryption mecha-
nisms and log systems, check if all the software installed were properly updated or if unusual traffic
inside its networks appears.
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Figure 6: PCI-DSS specificaton for storing sensitive data
After analyzing all the available documents we understood that Heartland were conscious about
risks of a cyber attack but nonetheless, they did not built a concrete plan to prevent and mitigate
the attack. As a matter of fact it only became aware of the breach after eight months and exclusively
after Visa alerted it of suspicious payment activities.
In addition to the weaknesses already described, an improper application of the principles of "least
privilege", which constitute one of the fundamental principle of software and organization security,
was present. Furthermore the absence of either external or internal penetration tests could have
been aware Heartland of vulnerabilities such as the SQL injection or the absence of a complete
logging system.
To conclude another important company behavior that favored the huge amount of data leak
was the, not taken, decision to temporary stop their system for further investigation on the event.
Though this would have caused some financial loss, the consequences would have been far less
catastrophic than the current one. Hence a better risk management policy that requires to halt
system on security breaches would have surely limited the damages.
5 Framworks Analysis
5.1 NIST Framework
Figure 7: NIST Five functions
The NIST framework is a collection of com-
puter security policies directed to a pri-
vate organization which aims to improve
their countermeasure against cyber attacks.
The framework is composed by three parts,
namely the "Core", which contains a set of
various aspects and approaches to cyber-
security, the "Profile", which basically is
the list of outcomes chose by the organiza-
tion based on their needs and, finally, the
"Tiers", which specifies organization’s view
of cyber-security risks and how they ap-
proach them. The following analysis is fo-
cused on the "Core" since the other two parts
are related to a business decision and would
not be so valuable for the purposes of this
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The core is again divided into five functions and, as stated in the official documentation, "They act as the
backbone of the Framework Core that all other elements are organized around"7. The functions are8:
Identify: managing cyber-security risk to systems, people, assets, data, and capabilities.
Protect: plans appropriate safeguards to ensure delivery of critical infrastructure services.
Detect: defines the appropriate activities to identify the occurrence of a cyber-security event.
: includes appropriate activities to take action regarding a detected cyber-security inci-
: identifies appropriate activities to maintain plans for resilience and to restore any capa-
bilities or services that were impaired due to a cyber-security incident.
Our choice fell on this framework due to its characteristic of having, for each element, an extensive reference
to a variety of other frameworks (like ISO-27001) , allowing for a better comparison with the next one (SANS-
In addition, we have discovered that the official Italian cyber-security framework was inspired by the NIST
so this seems to us the most educative choice.
5.1.1 How could have prevented hackers breach?
The NIST framework study is started by listing some controls that might have prevented the breach in various
ways, from the identification of software to incident response. Despite those controls alone would have
only slowed down the attackers, a whole and correct application of them would have hardened Heartland’s
ID Summary.
ID.AM-2 Software platforms and applications within the organization are inventoried.
ID.RA-1 Asset vulnerabilities are identified and documented.
Access permissions and authorizations are managed, incorporating the principles of
least privilege and separation of duties.
A baseline configuration of information technology/industrial control systems is
created and maintained incorporating security principles.
The principle of least functionality is incorporated by configuring systems to provide
only essential capabilities.
DE.DP-2 Detection activities comply with all applicable requirements.
DE.CM-4 Malicious code is detected.
DE.CM-8 Vulnerability scans are performed.
RS.AN-2 The impact of the incident is understood.
RS.MI-2 Incidents are mitigated.
To begin with, the outcomes that belong to the "Identify" function is presented. The fact that the company
still used a near decade-old software is already described in the weakness section( 4). By combining
Heartland would have been created a detailed ledger of installed application with
their relative know vulnerabilities listed, which might have worried some executive.
7Official Training:
8Description are taken from the official training
9Italian Cybersecurity Framework website:
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From a more technical perspective, despite the presence of a vulnerability in the web login form, hackers
would not have caused so much damage if the database software did not run with administrative privilege.
That is why a policy that enforced the usage of
, with a particular attention to the principle of "least
functionality" ( PR.AC-4 and PR-PT-3), would have limited intruder capabilities.
After that the controls that would have "contained" the breach after the Heartland discovered the intrusion
for the first time between 2007 and 2008[2].
First of all, once the breach was detected, employees believed that hackers were confined into the internal
network while in reality they already gained access to the payment network. In this case, if company
members were specifically trained to deal with this situation, like the policy
requires, the network
would have been immediately halted consequently causing mitigated damage in accordance with
To conclude, when the breach was initially discovered, an effective application of
would have spotted both the presence of intruders in the payment network and the weakness that they
had exploited. Instead, external security auditors were engaged and (unsurprisingly) failed to observe any
strange event.
5.1.2 How could have detected the breach?
Obviously, this section heavily relies on the "Detect" function, even though two elements belonging to
"Protect" and "Respond" were chosen.
The heartland lack of a reliable logging system has been already discussed earlier (4) just like the ineffective
network monitoring tool (4). In the following table, we have selected the most fitting outcomes that would
have detected the data breach.
ID Summary.
Audit/log records are determined, documented, implemented, and reviewed in
accordance with policy.
A baseline of network operations and expected data flows for users and systems is
established and managed.
DE.AE-2 Detected events are analyzed to understand attack targets and methods.
DE.CM-1 The network is monitored to detect potential cyber-security events.
Monitoring for unauthorized personnel, connections, devices, and software is per-
DE.DP-2 Detection activities comply with all applicable requirements.
RS.MI-1 Incidents are contained.
By analyzing the event according to their temporal order, applying the
would have drastically changed the attack result. When the web login page was exploited the first time, a
network monitor would have immediately detected the injection and then, considering that requirement
imposes well-designed logging system, the event would have been rapidly studied to identify and
(subsequently) patch the vulnerability. At the same time once a cyber-security breach is detected, following
would have required the company to temporarily halt their system until further investigation
ensures that every exploited vulnerability has been patched and that no backdoor is present. In our case
study, a premature detection would for sure changed the course of the event since Heartland’s executive
might consequently have improved their security policies (DE.DP-2).
If the criminals managed to elude the network monitor on the exploitation of the web vulnerability, other
alarms should have been triggered. When the attackers conducted reconnaissance on the internal network
a monitor which follows the requirements of
would immediately detect something like a port
scanning coming from database host.
Lastly, a clear and detailed set of allowed network operation specific for each connection, devices or software
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(as specified in
) would, without doubt, immediately expose flaw which allowed sensitive cardholder
data to flew in clear-text across the payment processing network.
5.2 How could have protected the stolen data?
This section, which is entirely composed by outcomes belonging to the "Protection" function, focuses on
ways that Heartland could have used to keep critical data safe.
ID Summary.
Identities and credentials are issued, managed, verified, revoked, and audited for
authorized devices, users and processes.
Users, devices, and other assets are authenticated (e.g., single-factor, multi-factor)
commensurate with the risk of the transaction (e.g., individuals’ security and privacy
risks and other organizational risks).
PR.DS-2 Data-in-transit is protected.
PR.DS-5 Protections against data leaks are implemented.
PR.AT-1 All users are informed and trained.
Firstly the weak authentication policy is studied. In the "Weak Password Policy" section (4) is explained
that the hackers managed to obtain valid credential only because some system had used a weak password.
By studying the PCI-DSS compliance it is noticed that only an obscene password security policy is present.
The very last version of the standard [
] states
that a password must be "at minimum length of at least
seven characters" which could be cracked in few hours by a modern computer.
). In addition it also
specifies that password must be changed at least once every 90 days, while nowadays this is considered
very bad practice since often the new password is easily-guessable.
With such password policies, it is
clear how hackers succeed in finding valid credential.
In contrast, NIST framework takes credentials very seriously. Firstly the policy
requires that
employees must be trained on security best-practices, such as password complexity rules, while on
is suggested to strengthen the authentication mechanism according to the user privileges and roles (like
implementing multi-factor authentication). The final policy regarding password is
that put strict
control on identities by forcing them to be issued, verified and revoked for various entities, such as devices,
users and even processes.
After that the approach of NIST against sensitive communication is analyzed. As written above (4) the lack
of a precise assets data flow scheme was the main responsible for the transit of un-encrypted data through
the internal network. In addition, the PCI-DSS instruct about weak security protection which focuses on
segmenting the network[
where cardholder data transit but say nothing about encryption
. This
security approach is entirely based on the assumption that an attacker would not have been able to access
the process-payment network and was very likely to be the big mistake the company has done. Any serious
security audit (apart from the PCI-DSS compliance) would have been reported a critical flaw like this one.
Also, in this case, NIST framework would have corrected the problems. With the
even if hackers
managed to steal sensitive data they would not have been able to retrieve them since external connection
would not be allowed in the restricted network. For example, a simple whitelist of allowed IPs address
would have stopped them from using their own server to store malware and data[
]. Despite these various
techniques exists to exfiltrate data out of a protected network. Instead, the real policy that would have
completely stopped the thieves is R.DS-2, which demands that all the data in transit should be encrypted.
10In section 8.2.3, 8.2.4
According to this site which also considers the computational power in 2007:
12Government Article link
13In "Network Segmentation" paragraph
14The only required encryption is when data transit over public network (Requirement 4).
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5.3 SANS Framework - CIS Controls
The "Critical Security Controls for Effective Cyber Defense" (CIS Controls)
is claimed to be a leading
framework used in cyber security assessments.
The CIS Controls are a prioritized set of actions that collectively form defense-in-depth guidelines of
best practices that mitigate the most common attacks against systems and networks. One of the main
characteristics of the CIS Controls is they are developed by experts based on their first-hand experience
in the security field and are derived from actual threat data from a variety of public and private sources.
Also, in addition to being prioritized and relevant, they are regularly updated to stay in step with the
cybersecurity’s ever-changing threat environment.
What should be understood about CIS Controls is that is not a one-size-fits-all solution, in either content or
Who decides to follow this set of rules has to understand what is critical to its business, data, systems,
networks, and infrastructures, and it has to consider the adversary actions that could impact its business.
This means that by following these criteria we started filtering each subcategory of the 20 controls listed,
choosing which controls suited better to Heartland case.
5.3.1 How could have prevented hackers breach?
"Prevent" means keeping something from occurring, so results quite obvious that CIS Controls chosen for
this section have the aim of taking actions and adopt behaviors before something bad happens.
As we properly analyzed in Risk and control weaknesses section (4) to prevent the breach Heartland should
have implemented a complete cyber-security policy achieving consequently a better knowledge of their
entire infrastructure.
In the table below CIS Controls that better describe the actions and decisions that should have been made
to prevent the breach are presented.
ID Summary.
2.8 Implement Application Whitelisting of Libraries.
2.9 Implement Application Whitelisting of Scripts.
3.1 Run Automated Vulnerability Scanning Tools.
16.3 Require Multi-factor Authentication.
18.2 Ensure Explicit Error Checking is Performed for All In-house Developed Software.
18.6 Ensure Software Development Personnel are Trained in Secure Coding.
18.10 Deploy Web Application Firewalls.
18.11 Use Standard Hardening Configuration Templates for Databases.
20.2 Conduct Regular External and Internal Penetration Tests.
Control 2.8
are widespread techniques used to limit the diffusion of malware inside a network
and single devices due to the fact that only the execution of trusted scripts and libraries is allowed,
preventing malicious code from performing harmful actions. On the other hand
Control 3.1, 18.6,
could have prevented the initial SQL injection which started the entire attack. In addition to that, it
could also be considered useful the
control 20.2
because almost surely a well-done and comprehensive
penetration test, maybe led by some external team, could have notified Heartland about the various
already discussed weaknesses that afflict the entire system.
Control 18.10
instead might have blocked the
SQL injection exploitation since WAFs are instructed to spot and deny unusual request, such as the one
15Offical description of the framework is taken from
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generated during a SQL injection, along with high traffic load.
To conclude,
control 16.3
would have been secured assets login, preventing hackers from gaining access
to the system just by cracking passwords, in fact with such mechanism an additional authentication layer is
necessary to gain access.
5.3.2 How could have detected the breach?
As was done for the NIST framework in this section the CIS Controls that could have detected the hacker’s in-
trusion inside the system have been chosen, and all the other problems arisen from this are briefly described.
ID Summary.
6.3 Enable Detailed Logging.
6.7 Regularly Review Logs.
9.2 Ensure Only Approved Ports, Protocols and Services Are Running.
9.4 Apply Host-based Firewalls or Port Filtering.
12.2 Scan for Unauthorized Connections.
12.5 Configure Monitoring Systems to Record Network Packets.
12.8 Deploy NetFlow Collection on Networking Boundary Devices.
13.3 Monitor and Block Unauthorized Network Traffic.
16.13 Alert on Account Login Behavior Deviation.
Control 6.3 and 6.7
belong to the absence of a complete logging system (4) and suggest to include
detailed information such as an event source, date, source and destination address within the log of each
host of the network. It is emphasized also to check regularly the logs generated to detect if there were any
malicious attempt to enter inside the system and corrupt it. As a matter of fact, CIS Controls guidelines
suggest to configure servers inside the network in order to create access control logs when a user attempts
to access resources without the appropriate privileges.
Usually, attackers search for remotely accessible network services that are vulnerable to exploitation.
Control 9.2 and 9.4
highlight the importance to take note of which ports and protocols are really
necessary to make the system work and to apply a default-deny rule that drops all traffic except those
services and ports that are explicitly allowed. Always within network weaknesses
control 12.2, 12.5 and
focus their attention on boundaries, which usually are the Achilles heel of network infrastructures.
Therefore check and log the traffic on boundaries could have prevented and detected the attack especially
when the hackers tried to pass from one network to the other.
Even if the asset of
control 13.3
is "data" and not even more "network" also this one emphasized
the importance of examining packets that pass through network perimeters, maybe by developing an
automated tool that blocks traffic of sensitive data and alerts immediately when this happens. Indeed it is
important that an organization, such as Heartland, understand what its sensitive information is, where it
resides, and who needs access to it. Although once the hackers were inside the network many actions could
have done to obfuscate the data stolen, adopting
control 13.3 and 16.13
together would have made the
life of the attackers really hard. As a matter of fact, monitoring the behavior of logged account would have
notified an abnormal time-of-day or workstation location and duration of user activities controlled by the
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5.3.3 How could have protected the stolen data?
In case that the attackers managed to enter anyway inside Heartland systems even with all the previous
controls properly implemented, CIS Controls suggests the correct behaviour in order to protect data from
malicious entities.
ID Summary.
4.4 Use Unique Passwords.
14.4 Encrypt All Sensitive Information in Transit.
As a matter of fact
control 4.4
could have been useful as an alternative of multi-factor authentication
where this was not supported. Adopt "unique" password means do not use the same password for all
the services and resources of the system, which is one of the most widespread advice in the field of
Definitely seen how the attack actually happened and how the data was stolen the
control 14.4
surely has
mitigated the damage of the breach. Although the information in transit during payment processes might
have been stolen in any case, the use of a proper encryption algorithm always raises the level of security of
an entire system. As mentioned above PCI DSS standard does not say anything about data encryption
leaving a big hole in the security of a system.
6 Framework Comparison
After using both frameworks on the Heartland case we have identified major benefits and drawback of each
The NIST framework is widely developed and applied all over the world by huge corporation
and therefore
results more complete and specific; appropriate for large companies that can afford an entire security team.
In fact, due to its length and verbosity, a medium/small company who chose to adopt it may start a very
time-consuming and resource-intensive review application process.
Despite it is divided into five macro-categories, which may seem to make it clearer, subcategories do not
contain a brief explanation but instead, a lot of references to other standards (like SANS, ISO27001) are
provided, making the decision process very tedious. Detailed description are contained in an external
document (NIST SP 800-53
) which precisely describe every aspect and action to carry on in order to
accomplish the standard.
On the other hand, the CIS Controls framework is divided into twenty specific categories that contain
various "sub-controls". For each of them, the relative asset is made explicit along with its security function
and a short description. Differently from the previous one, at the end of each category, there is a "Procedure
and Tools" section which explains, without being too technical, how to accomplish the control. This makes
it easier to understand and implement without too much effort, which suits-well for those who cannot
afford a specialized cyber-security team.
To conclude as far as we concerned both frameworks would have been helpful for Heartland case at the
time. The reality is that the company lacked of a concrete cyber-security policy and were only aware of the
possible risks involved. This catches the executives unprepared and unable to take the correct decision
which would have either prevent or mitigate the breach.
16NIST Success stories
17Official Link:
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7 Conclusion
Heartland data breach is probably one of the largest leak of credit card data ever, but at the same time is also
a valid example of how security policy should be implemented. The huge mistake that caused the event
was believing that a standard like the PCI-DSS, which is not intended to provide an extensive cybersecurity
prevention platform. Instead, applying a well-designed framework as the one studied (5) would have
definitely improved the situation.
After the 2008, incident the company started to take security very seriously. They have been re-listed in VISA
PCI compliant service providers and even calling standard for encryption within the payment industry[
However, on 8 May 2015, they suffered a break-in at the company’s offices in Santa Ana, California. This
time no sensitive data was officially stolen and Heartland responded quickly to the customers with a clear
]. To conclude, although the presented facts may seem an old story, nowadays the cybersecurity
world is still affected by what happened about 10 years ago.
Recently a huge dump of credentials which counts nearly 2.2 billion entries started to circulate on the dark
web forum and expert states that some of the data is related to the Heartland breach of 2008[
], which
demonstrate how consequences of a data breach could persist for a long time.
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Linda McGlasson Heartland Breach: Inside Look at the Plaintiffs’ Case URL: October
8, 2009
Kim ZetterKim Zetter TJX Hacker Charged With Heartland, Hannaford Breaches URL: August 17, 2009
Brian Krebs Payment Processor Breach May Be Largest Ever URL:
January 20, 2009
filings/1144354/000119312508051380/d10k.htm.pdf Page 23
Linda McGlasson Heartland Data Breach: Is End-to-End Encryption the Answer? URL: May
11, 2009
[7] Joint USSS/FBI Advisory URL: "20090212-usss_fbi_advisory.pdf "
Matthew Cochrane Why U.S. Counterfeit Credit Card Fraud Is Down 75% URL:
Nilson Report Card Fraud Worldwide URL :
Direct Download:
Jaikumar Vijayan Heartland breach expenses pegged at $140M so far URL:–140m—
Heartland URL:
Scott Ikeda The Data Dump of 2.2 Billion Breached Accounts: What You Need to Know URL:
what-you-need-to-know 9 Feb 2019
Kevin Judge The Heartland Breach: A Cautionary Tale for E-Commerce URL: 15 Oct
ResearchGate has not been able to resolve any citations for this publication.
Breach: Inside Look at the Plaintiffs' Case URL
  • Heartland Linda Mcglasson
Linda McGlasson Heartland Breach: Inside Look at the Plaintiffs' Case URL: October 8, 2009
Counterfeit Credit Card Fraud Is Down 75% URL
  • U S Matthew Cochrane Why
Matthew Cochrane Why U.S. Counterfeit Credit Card Fraud Is Down 75% URL:
Kevin Judge The Heartland Breach: A Cautionary Tale for
  • E-Commerce Url
Kevin Judge The Heartland Breach: A Cautionary Tale for E-Commerce URL: 15 Oct 2013