AccidentalFinancial ServicesFinanceMisdeliveryCustomer Data InvolvedEmployee Data InvolvedIdentity (basic)Government IDPIIMediumResolved

WILLIS NORTH AMERICA INC.

bd_cc28a57ab3fb9b89 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Mar 19, 2014

Filed

Apr 17, 2014

To disclose

29 days

Affected

47state residents only

Linked

3 filings

Confidence

66%

Full breach record for WILLIS NORTH AMERICA INC. →2 incidents on file

Willis North America Inc. Medical Expense Benefit Plan notified NH AG of a misdelivery incident on March 19, 2014. An administrator accidentally emailed a spreadsheet containing PII (SSN, DOB, names) to enrolled employees. 47 NH residents affected. No improper use detected. Remediation included deletion of copies and 2 years of ID theft protection.

J jump to incidentP pin to compareR raw source

Incident timeline

discovery → filing · 29 days

Mar 19, 2014

Begins

Mar 19, 2014

Discovered

Apr 17, 2014

Filed

vs. sector median

4 wks faster

This filing is one of 3 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (2) · sorted by filing gap

Massachusetts State AGbd_542164c507117ae12014-04-22 · +5dVerified
HHS OCRbd_ee1b0a75f296a2f02014-04-24 · +7dVerified

Name: WILLIS NORTH AMERICA INC.
norm: willis north america
Domain: willis.com

Name: WILLIS NORTH AMERICA INC.
norm: willis north america
Industry: Financial Servicesllm

Discovered: Mar 19, 2014
Breach occurred: Mar 19, 2014
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: Mar 19, 2014
Affected individuals: 47state-resident count only
Data types: Identity (basic)Government IDPII
Data elements: Social Security numberDate of birth
Attack vector: Unknown
MITRE ATT&CK: T1535 Unused/Unsupported Cloud Storage
Threat actor: Internal

During the incident: Tracking and ensuring the deletion of any forwards of the email
Blocking the ability to forward the email
Deleting the email from recipient inboxes
Instructing all recipients to delete any remaining copies
Arranged for two years of ID theft protection at no charge
Completed an internal review of how the error occurred
Implementing changes designed to prevent recurrence
Changes made: Tightening procedures to help prevent such an incident in the future
Reviewing and strengthening data security practices
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 29 days(29 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 3 filings · 3 states

View merged incident ↗

New Hampshire State AGApr 17 · first · this page

Massachusetts State AG+5d

HHS OCR+7d

Pattern: first filing Apr 17 (NH), last Apr 24 (NY) — a 7-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://mm.nh.gov/files/uploads/doj/remote-docs/willis-north-america-20140417.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Apr 17, 2014
Raw hash: 3201f91bc0877f87a77a247b510fcfbb8d4b0560223f41a45e8a7dbd015ecaad

Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityWILLIS NORTH AMERICA INC.

Victim entityWILLIS NORTH AMERICA INC.

Incidentdiscovered Mar 19, 2014

Stated responseTracking and ensuring the deletion of any forwards of the email

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov