Democracy Data & Communications, LLC (

In its breach report and during the course of OCR's investigation, the covered entity advised that it took various corrective actions to prevent a reoccurrence of the breach. Specifically, the covered entity conducted a risk assessment which revealed that the breach posed a significant risk of financial, reputational, or other harm to the 83,000 members. The covered entity sent notification letters to 83,000 members apologizing for the breach and offered a year of free credit monitoring and a $25,000 insurance policy against identity theft ($10,000 for New York residents). The covered entity also provided training to its call centers on November 29, 2009 to answer inquiries from callers concerned about the breach. In addition, media outlets were contacted to alert of a breach in states in which more than 500 members were impacted by the breach. The covered entity advised that media outlets were identified based on location of membership impacted, as well as ensuring it was a major media outlet and press releases were sent to 21 major media outlets on December 18, 2009. The covered entity also created and implemented a new policy titled 'Personal Health Information and Personal Identifiable Information Data Security and Handling Policy Acknowledgement Form' that centralized all data requests through a 'Team Track' which is an internal electronic submission request that ensures all PHI requested data receives the sign off of the Privacy Officer and Security Officer prior to release. Further, the covered entity also provided a mandatory annual computer-based training to all staff in May 2010. \