North Memorial Health Care
bd_c4c4677a70f9b72d · schema v1 · pii pii-v1
Full breach record for North Memorial Health Care →2 incidents on fileRegulator'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.
North Memorial Health Care settled charges of potentially violating HIPAA Privacy and Security Rules by failing to execute a business associate agreement with a major contractor and failing to conduct an organization-wide risk analysis. The settlement includes a $1,550,000 payment and a corrective action plan.
J jump to incidentP pin to compareR raw source
Incident timeline — partial
? — ?
Breach window unknown
Mar 16, 2016
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 (1) · sorted by filing gap
- HHS OCRbd_f84bf96ec2ae47702011-09-27 · +1632dCandidate
Filing propagation · 2 filings
View merged incident ↗Pattern: first filing Sep 27 (MN), last Mar 16 — a 1632-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.