FLORIDAMisuseHealthcareHealthcareEmail MisuseCustomer Data InvolvedEmployee Data InvolvedData ExfiltratedHealth (basic)Identity (basic)Financial accountLowResolved

Pathway to Hope

bd_1e04a72e1f70e03e · schema v1 · pii pii-v1

Severity

Low

Discovered

Jan 1, 2015

Filed

Feb 12, 2015

To disclose

6 weeks

Affected

600

Confidence

95%

Full breach record for Pathway to Hope →

Pathway to Hope (FL, Healthcare Provider) reported to HHS on 2015-02-12 an Unauthorized Access/Disclosure affecting 600 individuals. In January 2015, a former employee emailed PHI — including full names, referral sources, insurance information, and mental health/substance abuse diagnoses — to her personal email account before her last day of employment, intending to build her own practice. Breached information was located in Email. OCR provided technical assistance and obtained assurances of corrective actions including workforce training, revised policies, and hiring of a compliance officer.

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HIPAA clock✓ HHS report on time6 weeks discovery → filing

⚠ occurrence dateThe stored discovery date equals the breach OCCURRENCE date. Detection is normally later, so this OVERSTATES the delay — a 'late' verdict here may not be real.

Incident timeline

discovery → filing · 6 weeks / 42 days

Jan 1, 2015

Begins

Jan 1, 2015

Discovered

Feb 12, 2015

Filed

vs. sector median

7 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed600 affectedView incident

Name: Pathway to Hope
norm: pathway to hope
Industry: Health Care Services

Name: Pathway to Hope
norm: pathway to hope
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Jan 1, 2015
Breach occurred: Jan 1, 2015
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 600nationwide
Data types: Health (basic)Identity (basic)Financial account
HHS breach type: Unauthorized access or disclosure
Where the data lived: Email
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1052 Exfiltration Over Physical MediumT1114 Email Collection
Threat actor: InternalFinancial
Regulator citations: HHS OCR notified; OCR provided technical assistance regarding Privacy, Security and Breach Notification Rules; OCR obtained assurances of corrective action implementation.
Initial access: insider_action

During the incident: Counseled workforce members
Improved training program
Substantially revised policies and procedures
Hired a compliance officer
Required employees to sign non-compete, non-solicitation, and confidentiality agreements
Changes made: Workforce counseling
Updated training program
Revised policies and procedures
Compliance officer hired
Non-compete and confidentiality agreements implemented
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 6 weeks(42 days from discovery to filing)
Compliance flags: HHS report on timeHHS notified
Discovery-date grounding: occurrence dateThe stored discovery date equals the breach OCCURRENCE date. Detection is normally later, so this OVERSTATES the delay — a 'late' verdict here may not be real.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: Jan 1, 2015
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Jan 1, 2015
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Jan 1, 2015 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Jan 1, 2015 → Notified: not extracted	—	regulatory submission	HHS notified

Status: No extraction artifact recorded for this disclosure.

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.

Source URL: https://ocrportal.hhs.gov/ocr/breach/breach_report.jsf
DisclosureLens renders the full SEC/HHS filing inline below from the originating regulator’s public record (§4.5 fair report privilege).
Filed at: Feb 12, 2015
Raw hash: 9216467da9a22af6d7cdc223d0df9250391322b71ab24b768c164330e0aa01dd

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Reporting entityPathway to Hope

Victim entityPathway to Hope

Incidentdiscovered Jan 1, 2015

Stated responseCounseled workforce members

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing