The Arc of Erie County

Two spreadsheets containing the protected health information (PHI) of 3,751 individuals became available for public access via the internet due to a security protection failure on a hyperlink designed for internal use on the covered entity’s (CE) website. The breached PHI included demographic, clinical, and health insurance information. The CE provided breach notification to HHS, the affected individuals, and the media. Following the breach, the CE turned off internet access to hyperlinks that contained PHI. In addition, the CE engaged Avalon, a cyber-security forensic investigation company to conduct a comprehensive review of its HIPAA compliance, including it data privacy and security, and IT policies and procedures. Avalon will also provide the CE, on an ongoing basis, active managed detection and response services. Further, the CE hired a new IT director and purchased and implemented patch management software to reduce vulnerabilities, as well as intrusion detection software. The CE also engaged another information security company, HarpData, to conduct a risk assessment of its IT system. OCR obtained assurances that the CE implemented the corrective actions listed.