DisclosureLens
AccidentalFinancial ServicesFinanceMisdeliveryCustomer Data InvolvedGovernment IDIdentity (basic)Financial accountMediumResolved

TSYS Merchant Solutions

bd_11834c3d004c7794 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Nov 14, 2016

Filed

Dec 5, 2016

To disclose

21 days

Affected

Not disclosed

Confidence

64%

TSYS Merchant Solutions inadvertently copied a partner bank representative on an email containing a TIN Mismatch file for merchants. The file included Merchant Identification Numbers, merchant names, and Tax Identification Numbers (or SSNs). The bank representative immediately deleted the file. TSYS notified affected merchants on November 29, 2016, regarding the incident that occurred on November 14, 2016.

California clockDiscovered Nov 14, 2016Notified Nov 29, 201615d CA 60-day OK21 days discovery → filing

Incident timeline

discovery → filing · 21 days

Nov 14, 2016

Begins

Nov 14, 2016

Discovered

Dec 5, 2016

Filed

vs. sector median

6 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.ConfirmedView incident

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.