NEW JERSEYMisuseHealthcareHealthcareMisuse OtherData MishandlingCustomer Data InvolvedData ExfiltratedEmployee Data InvolvedHealth (basic)Identity (basic)Government IDMetadataMediumResolved

First Step Counseling, Inc.

bd_4e2d7b2f6a3c34e3 · schema v1 · pii pii-v1

Severity

Medium

Discovered

—

Filed

Oct 23, 2012

To disclose

—

Affected

638

Confidence

97%

Full breach record for First Step Counseling, Inc. →

From May 1 to August 5, 2011, two employees of First Step Counseling, Inc. (NJ) made unauthorized photocopies of documents containing 638 patients' PHI — including names, insurance numbers, diagnoses, dates of birth, phone numbers, and SSNs — and disclosed them to their personal attorney. The CE notified HHS, affected individuals, and the media. Following an OCR investigation, the CE implemented corrective actions including an electronic billing system, locked patient files, and physical front-desk safeguards. Breached information located on Paper/Films.

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HIPAA clock✓ HHS notified

⚠ no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.

⚠ No discovery dateThe OCR public portal omits the discovery date, so the 60-day notification clock cannot be evaluated from this source — only that the filing was submitted.

Incident timeline

May 1, 2011

Begins

Oct 23, 2012

Filed

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed638 affectedView incident

Name: First Step Counseling, Inc.
norm: first step counseling
Industry: Health Care Services

Name: First Step Counseling, Inc.
norm: first step counseling
Industry: Health Care Services
Industry: Healthcaresource default

Discovered: Not extracted — the OCR public portal omits it
Breach occurred: May 1, 2011 – Aug 5, 2011
Materiality determined: —
Notification sent: —
Affected individuals: 638nationwide
Data types: Health (basic)Identity (basic)Government IDMetadata
HHS breach type: Theft
Where the data lived: Paper / films
Covered-entity type: Healthcare provider
Attack vector: Unauthorized Access
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: Internal
Regulator citations: OCR investigation completed; corrective action plan accepted by OCR
Initial access: insider_action

During the incident: Hired attorneys to seek immediate return of all photocopied PHI
Provided breach notification to HHS, affected individuals, and the media
Changes made: Transferred to a password-protected electronic billing system
All patient files locked/unlocked exclusively by the office manager
Front desk protected by a window
Patients prohibited from standing beside the receptionist desk
Source: Quoted from the filing itself, not independently verified.

Compliance flags: HHS notified
Discovery-date grounding: no discovery dateNo discovery date was extracted, so no notification clock can be evaluated.
Clock breakdown: Statute Window Elapsed Threshold Status
HIPAA
Discovered: not extracted
→ Notified: not extracted
— regulatory submission HHS notified

Statute	Window	Elapsed	Threshold	Status
HIPAA	Discovered: not extracted → 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: Oct 23, 2012
Raw hash: 20179ca8e3867d3c06e400139eec5e89a799b5799fc57ea75e58c0fe5f3d7633

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Reporting entityFirst Step Counseling, Inc.

Victim entityFirst Step Counseling, Inc.

IncidentUnauthorized Access

Stated responseHired attorneys to seek immediate return of all photocopied PHI

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing