ALABAMAPhysicalHealthcareHealthcareTheftCustomer Data InvolvedHealth (basic)Identity (basic)Government IDFinancial accountFinancialMediumResolved

Pathways Professional Counseling

bd_2590d91f803c2789 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Sep 25, 2015

Filed

Nov 24, 2015

To disclose

9 weeks

Affected

986

Confidence

98%

Full breach record for Pathways Professional Counseling →

On September 25, 2015, an employee's unencrypted, password-protected laptop was stolen from his vehicle. The device contained PHI of 985 patients including names, addresses, dates of birth, SSNs, clinical diagnoses, financial information, email addresses, physician information, health insurance, treatment, and medication information. Pathways Professional Counseling (AL) reported the breach to HHS on 2015-11-24, affecting 986 individuals. OCR obtained assurances of corrective actions including encryption, employee retraining, policy revisions, and employee sanction.

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HIPAA clock✓ HHS report on time9 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 · 9 weeks / 60 days

Sep 25, 2015

Begins

Sep 25, 2015

Discovered

Nov 24, 2015

Filed

vs. sector median

4 wks faster

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed986 affectedView incident

Name: Pathways Professional Counseling
norm: pathways professional counseling
Industry: Health Care Services

Name: Pathways Professional Counseling
norm: pathways professional counseling
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Sep 25, 2015
Breach occurred: Sep 25, 2015
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: —
Affected individuals: 986nationwide
Data types: Health (basic)Identity (basic)Government IDFinancial accountFinancial
HHS breach type: Theft
Where the data lived: Laptop
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: External
Regulator citations: HHS OCR — corrective action assurances obtained

During the incident: Provided breach notification to HHS, affected individuals, and the media
Engaged third party to encrypt computers
Retrained employees with access to PHI
Revised HIPAA Compliance Plan
Implemented policy requiring encryption for mobile devices before access is granted
Implemented policy requiring reasonable security measures for employee-owned electronic devices
Sanctioned the employee involved in the breach
Changes made: Full-disk encryption deployed on computers via third-party vendor
Mobile device encryption policy enacted
BYOD security policy enacted
Employee retraining on PHI handling
HIPAA Compliance Plan revised
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 9 weeks(60 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: Sep 25, 2015
→ Notified: not extracted
— 60 days HHS report on time
HIPAA
Discovered: Sep 25, 2015
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: Sep 25, 2015 → Notified: not extracted	—	60 days	HHS report on time
HIPAA	Discovered: Sep 25, 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: Nov 24, 2015
Raw hash: e8b85d8d7f0c0429396df3eb648bcb59c28614c739303979214ceb5a01aacad1

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Reporting entityPathways Professional Counseling

Victim entityPathways Professional Counseling

Incidentdiscovered Sep 25, 2015

Stated responseProvided breach notification to HHS, affected individuals, and the media

ComplianceHHS report on time

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing