HackingEducationEducationDelayed DiscoveryCustomer Data InvolvedIdentity (basic)Government IDMediumContained

Pharmacy Times Office of Continuing Professional Education, LLC

bd_62074ff78d72913f · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jul 6, 2018

Filed

Nov 13, 2018

To disclose

19 weeks

Affected

797state residents only

Linked

7 filings

Confidence

71%

Full breach record for Pharmacy Times Office of Continuing Professional Education, LLC →

Pharmacy Times Office of Continuing Professional Education, LLC reported unauthorized access to a publicly available file containing client PII (names, SSNs) between May 11 and July 6, 2018. The incident was discovered on July 6, 2018. Notices were sent to 797 Washington residents starting November 13, 2018, offering 12 months of credit monitoring.

J jump to incidentP pin to compareR raw source

Incident timeline

undetected · 56 days

discovery → filing · 19 weeks / 130 days

May 11, 2018

Begins

Jul 6, 2018

Discovered

Nov 13, 2018

Filed

vs. sector median

+10 wks slower

This filing is one of 7 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (6) · sorted by filing gap

Oregon State AGbd_5a13493eb8231c712018-11-13Candidate
Massachusetts State AGbd_ee8911aec0566b682018-11-13Verified
New Hampshire State AGbd_aeb69775153a7b892018-11-19 · +6dVerified
California State AGbd_61c59abe6c8162592018-11-26 · +13dVerified

Show 2 more filings ↓up to 85d gap

Montana State AGbd_41994e74a3d0a96c2019-02-06 · +85dVerified
New Hampshire State AGbd_e5ba9a8b0f81201a2019-02-06 · +85dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: Pharmacy Times Office of Continuing Professional Education, LLC
norm: pharmacy times office of continuing professional education
Industry: Educationllm

Discovered: Jul 6, 2018
Breach occurred: May 11, 2018 – Jul 6, 2018
Undetected for: 56 daysoccurrence → discovery
Materiality determined: —
Notification sent: Nov 13, 2018
Affected individuals: 797state-resident count only
Data types: Identity (basic)Government ID
Data elements: NameSocial Security number
WA-stated cause: Unauthorized Access
WA-stated duration: lifecycle 100-199dexposure 1-99d
WA-stated discovery: Found after the fact
Attack vector: Unauthorized Access
MITRE ATT&CK: T1190 Exploit Public-Facing Application
Threat actor: External
Regulator citations: Notified Washington Office of the Attorney General
Initial access: exploit_public_facing

During the incident: Began working with third-party forensic investigators to determine the nature and scope of the potential data event
Removed the file from the web server
Provided written notice to those individuals who may be affected by this incident
Providing the twenty-four (24) Washington residents who will receive notice of this event access to one (1) year of complimentary credit and identity monitoring services and identity restoration services through Kroll
Providing potentially impacted individuals with guidance on how to better protect against identity theft and fraud
Providing written notice of this incident to other state regulators and the major consumer reporting agencies
Changes made: Working to implement additional safeguards to protect the security of information in its system
Working to review our existing policies and procedures and to implement additional safeguards to further secure the information in our systems
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 19 weeks(130 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 7 filings · 6 states

View merged incident ↗

Oregon State AGNov 13 · first

Massachusetts State AGNov 13 · first

Washington State AGNov 13 · first · this page

New Hampshire State AG+6d

California State AG+13d

Montana State AG+85d

New Hampshire State AG+85d

Pattern: first filing Nov 13 (OR), last Feb 6 (NH) — a 85-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

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://agportal-s3bucket.s3.amazonaws.com/databreach/BreachM10594.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Nov 13, 2018
Raw hash: 088d65674872a295d677cb77a4f50d6bf3eed54078fe920c977bc27adf1cfb0b

Linked disclosures

Regulatory filings (6) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityPharmacy Times Office of Continuing Professional Education, LLC

Incidentdiscovered Jul 6, 2018

Stated responseBegan working with third-party forensic investigators to determine the nature and scope of the potential data event

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenanceagportal-s3bucket.s3.amazonaws.com