MisuseHealthcareHealthcareData MishandlingEmployee Data InvolvedCustomer Data InvolvedDelayed DiscoveryPHIIdentity (basic)Government IDHealth (basic)Financial accountHighActive

The Neurology Foundation, Inc.

bd_3a9ac259bffb679c · schema v1 · pii pii-v1

Severity

High

Discovered

Apr 1, 2017

Filed

Sep 1, 2017

To disclose

18 weeks

Affected

11,516

Linked

3 filings

Confidence

67%

Full breach record for The Neurology Foundation, Inc. →

The Neurology Foundation, Inc. reported an insider threat incident where a former employee unauthorizedly transferred sensitive patient data, including PHI and financial information, to personal devices. The incident was discovered in late April 2017. Approximately 11,516 individuals were affected, including 7 New Hampshire residents. The Foundation engaged forensic investigators, notified law enforcement, and provided credit monitoring services.

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Incident timeline

discovery → filing · 22 weeks / 153 days

Apr 1, 2017

Discovered

Sep 1, 2017

Filed

vs. sector median

+7 wks slower

This filing is one of 3 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (2) · sorted by filing gap

Massachusetts State AGbd_3f963ff701da75542017-09-01Candidate
HHS OCRbd_58eaf4da7ee0d84b2017-09-01Verified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: The Neurology Foundation, Inc.
norm: the neurology
Industry: Healthcarellm

Discovered: Apr 1, 2017
Materiality determined: —
Notification sent: Sep 1, 2017
Affected individuals: 11,516state + nationwide
Data types: PHIIdentity (basic)Government IDHealth (basic)Financial account
Attack vector: Insider
MITRE ATT&CK: T1078 Valid AccountsT1052 Exfiltration Over Physical Medium
Threat actor: Internal
Regulator citations: Notified local law enforcement and the FBIProvided notice to the U.S. Department of Health and Human ServicesProvided notice to other state regulators
Initial access: insider_action

During the incident: Launched an investigation with the assistance of third-party forensic investigators
Recovered the hard drive and thumb drives
Terminated the employee
Notified local law enforcement and the FBI
Provided 12 months of credit and identity monitoring services through AllClear ID
Established a dedicated call center for potentially affected individuals
Provided guidance on how to better protect against identity theft and fraud
Posted notice of this incident on the homepage of its website
Provided notice of this incident to the U.S. Department of Health and Human Services and other state regulators
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 18 weeks(124 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 3 filings · 3 states

View merged incident ↗

Massachusetts State AGSep 1 · first

HHS OCRSep 1 · first

New Hampshire State AGSep 1 · first · 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://mm.nh.gov/files/uploads/doj/remote-docs/neurology-foundation-20170901.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Sep 1, 2017
Raw hash: c577f6e5756d4c83ac695af5a0a0cf1b9e5ffb5f35b0a9060758f8fb5e43c646

Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityThe Neurology Foundation, Inc.

Incidentdiscovered Apr 1, 2017

Stated responseLaunched an investigation with the assistance of third-party forensic investigators

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov