Warby Parker
bd_62d16c37bdd506f2 · schema v1 · pii pii-v1
Full breach record for Warby Parker →Regulator's decision — not a breach notification
This record is a regulator's decision, not the organisation's own breach notice. Breach-notification fields (discovery date, notification clock) are structurally absent — what this source establishes is the outcome and the provisions the decision cites.
HHS OCR imposed a $1.5M civil money penalty on Warby Parker, Inc. for HIPAA Security Rule violations. A credential stuffing attack in 2018 compromised ePHI of nearly 200,000 individuals. Violations included failure to conduct risk analysis, implement sufficient security measures, and review system activity logs.
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Incident timeline — partial
? — ?
Breach window unknown
Feb 20, 2025
Filed
—
Corroborated · see linked filings
Compliance clocks stay unassessable until a breach filing is linked. This record is the regulator's action, not a breach notice. Dashed segments fill in automatically when corroboration arrives.
Linked disclosures
Why this link?Regulatory filings (3) · sorted by filing gap
- Oregon State AGbd_2bfbb470bd46e7c92018-12-27 · +2247dVerified
- Montana State AGbd_8942611f8a369bd42018-12-20 · +2254dCandidate
- HHS OCRbd_93ff67dbc9f344b92018-12-20 · +2254dVerified
Filing propagation · 4 filings · 3 states
View merged incident ↗Pattern: first filing Dec 20 (MT), last Feb 20 — a 2254-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?
Evidence ladder
Attacker assertion only. Establishes: claim date, group, alleged victim.
Unlocks: incident narrative, operational impact. Still no compliance clock.
Unlocks: discovery date, data types, affected count, compliance clock.
Unlocks: materiality, stated response, full audit trail. Ceiling removed.
Source ceiling
- instrument + outcome
- amount as filed (USD)
- CFR provisions
- the breach it recites
- discovery date
- notification clock
The dates the agreement recites belong to the underlying breach, years earlier, and are kept as evidence of WHICH breach rather than as this record’s timeline.