AccidentalProfessional ServicesProfessional ServicesMisconfigurationCustomer Data InvolvedDelayed DiscoveryIdentity (basic)Government IDMediumContained

JWCH Institute, Inc.

bd_2695a4b2a374b40f · schema v1 · pii pii-v1

Severity

Medium

Discovered

Aug 16, 2021

Filed

Oct 26, 2021

To disclose

10 weeks

Affected

Not disclosed

Confidence

64%

Full breach record for JWCH Institute, Inc. →

Employee Benefits Administration & Management (EBA&M), a third-party administrator for JWCH Institute, Inc., inadvertently uploaded a file containing personal information (name, address, SSN, DOB) to a publicly accessible website on June 4, 2021. The error was discovered on August 16, 2021, and the file was removed. EBA&M is offering 12 months of credit monitoring and reviewing data management policies.

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California clockDiscovered Aug 16, 2021 → Notified Oct 22, 202167d ✗ CA 60-day late10 weeks discovery → filing

Incident timeline

undetected · 73 days

discovery → filing · 10 weeks / 71 days

Jun 4, 2021

Begins

Aug 16, 2021

Discovered

Oct 26, 2021

Filed

vs. sector median

9 wks faster

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

Name: Employee Benefits Administration & Management
norm: employee benefits administration management

Name: JWCH Institute, Inc.
norm: jwch institute
Industry: Professional Servicesllm

Discovered: Aug 16, 2021
Breach occurred: Jun 4, 2021 – Aug 16, 2021
Undetected for: 73 daysoccurrence → discovery
Materiality determined: —
Notification sent: Oct 22, 2021
Affected individuals: Not disclosed
Data types: Identity (basic)Government ID
Data elements: Social Security numberDate of birth
Attack vector: Unknown
Third party: via Employee Benefits Administration & Management

During the incident: Immediately launched an investigation to determine the nature and scope of the incident
Offering complimentary access to Experian IdentityWorks for twelve months
Changes made: Reviewing our policies and procedures relating to data management and security
Implementing additional training and education to our employees to reduce the risk of similar future incidents
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 10 weeks(71 days from discovery to filing)
Compliance flags: CA 60-day late · 67d
Discovery-date grounding: letter-groundedThe discovery date is the detection date narrated in the notification letter — the defensible tier.
Clock breakdown: Statute Window Elapsed Threshold Status
California
Discovered: Aug 16, 2021
→ Notified: Oct 22, 2021
67d 60 days (analyst band, pre-2026 discoveries) CA 60-day late

Statute	Window	Elapsed	Threshold	Status
California	Discovered: Aug 16, 2021 → Notified: Oct 22, 2021	67d	60 days (analyst band, pre-2026 discoveries)	CA 60-day late

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://oag.ca.gov/ecrime/databreach/reports/sb24-546898
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Oct 26, 2021
Raw hash: 5f91c722a7927e3e7ce4be43325281715848350b5785ccbdf57635569c7d91ce

Reporting entityEmployee Benefits Administration & Management

Victim entityJWCH Institute, Inc.

Incidentdiscovered Aug 16, 2021

Stated responseImmediately launched an investigation to determine the nature and scope of the incident

ComplianceCA 60-day late

Extraction provenanceno artifact recorded

Source provenanceoag.ca.gov