MisuseHealthcareHealthcarePrivilege AbuseEmployee Data InvolvedCustomer Data InvolvedBusiness Associate (HIPAA)PHIIdentity (basic)Government IDHealth (basic)HighContained

The Guidance Center, Inc.

bd_358b2d1e26150492 · schema v1 · pii pii-v1

Severity

High

Discovered

Mar 25, 2019

Filed

Oct 30, 2019

To disclose

31 weeks

Affected

1,235state residents only

Linked

2 filings

Confidence

66%

Full breach record for The Guidance Center, Inc. →2 incidents on file

The Guidance Center, a non-profit mental health agency, detected unusual activity on March 25, 2019, including deleted files and reconfigured remote access. Investigation revealed a former employee gained unauthorized remote access to certain email accounts containing PHI (names, SSNs, medical info) of 1,235 California residents. The incident occurred between March 15 and April 1, 2019. TGC engaged forensic experts, notified law enforcement (FBI, Long Beach PD), and restored systems. Affected individuals were notified on October 28, 2019, and offered one year of credit monitoring.

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California clockDiscovered Mar 25, 2019 → Notified Oct 28, 2019217d ✗ CA 60-day late31 weeks discovery → filing

Incident timeline

undetected · 10 days

discovery → filing · 31 weeks / 219 days

Mar 15, 2019

Begins

Mar 25, 2019

Discovered

Oct 30, 2019

Filed

vs. sector median

+20 wks slower

This filing is one of 2 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (1) · sorted by filing gap

HHS OCRbd_8be6cad5380514d52019-10-28 · +2dVerified by operator

Name: The Guidance Center, Inc.
norm: the guidance center

Name: The Guidance Center, Inc.
norm: the guidance center
Industry: Healthcarellm

Discovered: Mar 25, 2019
Breach occurred: Mar 15, 2019 – Apr 1, 2019
Undetected for: 10 daysoccurrence → discovery
Materiality determined: —
Notification sent: Oct 28, 2019
Affected individuals: 1,235state-resident count only
Data types: PHIIdentity (basic)Government IDHealth (basic)
Attack vector: Insider
MITRE ATT&CK: T1078 Valid AccountsT1074 Data StagedT1070 Indicator Removal
Threat actor: Internal
Regulator citations: Notified the California Department of Public HealthProvided notification of the incident to the U.S. Department of Health and Human Services’ Office for Civil Rights (“OCR”)
Initial access: insider_action

During the incident: Immediately commenced an investigation upon discovering this activity
Engaged independent cybersecurity experts for assistance
Took numerous steps to secure its systems
Engaged a data review firm to determine if the email accounts... contained protected health information
Reported this matter to law enforcement
Sent this former employee a cease-and-desist letter
Reported this matter to the Long Beach Police Department and FBI
Engaged a leading, independent digital forensics firm to conduct an investigation
Worked several weeks to restore and secure its systems
Offering twelve (12) months of complimentary credit monitoring and identity protection services through TransUnion
Changes made: Restored and secured its systems
Ensured operations were maintained
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 31 weeks(219 days from discovery to filing)
Compliance flags: CA 60-day late · 217d
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: Mar 25, 2019
→ Notified: Oct 28, 2019
217d 60 days (analyst band, pre-2026 discoveries) CA 60-day late

Statute	Window	Elapsed	Threshold	Status
California	Discovered: Mar 25, 2019 → Notified: Oct 28, 2019	217d	60 days (analyst band, pre-2026 discoveries)	CA 60-day late

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 2 filings

View merged incident ↗

HHS OCROct 28 · first

California State AG+2d · this page

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/sb24-183952
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Oct 30, 2019
Raw hash: 13096deff03ec9df8933c8e53a8a28ce9da0c1f74736f14457a5528ccadc7b01

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityThe Guidance Center, Inc.

Victim entityThe Guidance Center, Inc.

Incidentdiscovered Mar 25, 2019

Stated responseImmediately commenced an investigation upon discovering this activity

ComplianceCA 60-day late

Extraction provenanceno artifact recorded

Source provenanceoag.ca.gov