VIRGINIAPhysicalHealthcareProfessional ServicesHealthcareLossBusiness Associate (HIPAA)Customer Data InvolvedHealth (basic)Identity (basic)Government IDHighResolved

Towers Watson & Co.

bd_5fce7e7181f84840 · schema v1 · pii pii-v1

Severity

High

Discovered

—

Filed

Apr 27, 2010

To disclose

—

Affected

1,874

Confidence

96%

Full breach record for Towers Watson & Co. →2 incidents on file

Towers Watson, a business associate of General Agencies Welfare Benefits Program, lost two electronic media disks containing PHI while transporting them between BA offices. The disks held names, health plan numbers, and Social Security numbers of 1,874 individuals. The BA notified affected individuals and provided two years of credit monitoring. The CE notified HHS and media, posted substitute notice, had PHI destroyed or secured under a new BA agreement, and updated policies after OCR investigation.

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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 — partial

? — ?

Breach window unknown

Apr 27, 2010

Filed

No interval is drawn: no breach start or discovery date is on record for this filing.

Tracked as a single-filing incident — the only disclosure on record for this event so far.Confirmed1,874 affectedView incident

Name: Towers Watson & Co.
norm: towers watson
Industry: Business Associate

Name: Towers Watson & Co.
norm: towers watson
Industry: Business Associate
Industry: Healthcaresource defaultProfessional Servicesllm

Discovered: Not extracted — the OCR public portal omits it
Materiality determined: —
Notification sent: —
Affected individuals: 1,874nationwide
Data types: Health (basic)Identity (basic)Government ID
HHS breach type: Theft
Where the data lived: Other
Covered-entity type: Business associate
Attack vector: Unauthorized Access
MITRE ATT&CK: T1052 Exfiltration Over Physical Medium
Threat actor: Internal
Regulator citations: HHS OCR investigation completed; CE updated privacy and breach notification policies and procedures
Third party: via Towers Watsonbusiness associate

During the incident: BA notified all affected individuals
BA provided two years of enhanced credit monitoring services
CE notified HHS and the media
CE posted substitute notice on its website
CE required BA to destroy retained PHI
CE executed new BA agreement for archival PHI that could not be destroyed
Changes made: CE updated privacy and breach notification policies and procedures following OCR investigation
New business associate agreement executed for remaining archival PHI
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: Apr 27, 2010
Raw hash: bd8bb89cd376ee6a9cbab01f1512352468e16978bf5793b600b2fea40b4e992a

AI-assisted summary above. The structured extract on this page was generated from the document below. Inspect the source to verify or correct any field.

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Reporting entityTowers Watson & Co.

Victim entityTowers Watson & Co.

IncidentUnauthorized Access

Stated responseBA notified all affected individuals

ComplianceHHS notified

Extraction provenanceno artifact recorded

Source provenanceocrportal.hhs.gov

Source filing