What changed afterward
- The CE revised its confidentiality agreement and implemented enhanced access controls to prevent a reoccurrence.
Program action
Train on the specific failure, apply the sanction policy consistently, and verify the behaviour changed.
HIPAA §164.308(a)(5)(i), 164.308(a)(1)(ii)(C)
CISSP 1CISM 3CISA 2
Full OCR narrative
The covered entity (CE), Women’s Wellness of Southern Delaware, reported that an employee retained patient’s protected health information (PHI) without approval or authorization after employee’s employment with CE ended. According to the breach report, the breach affected approximately 1,347 individuals. The PHI involved clinical, demographic and other treatment information. The CE notified HHS, the media, and the affected individuals. The CE revised its confidentiality agreement and implemented enhanced access controls to prevent a reoccurrence. OCR provided technical assistance to the CE regarding the HIPAA Rules and received evidence substantiating the CE’s notifications.