DisclosureLens
PENNSYLVANIAAccidentalHealthcareProfessional ServicesHealthcarePublishing ErrorBusiness Associate (HIPAA)Customer Data InvolvedHealth (basic)Identity (basic)Government IDHighResolved

Aon

bd_ecfa091902c2846e · schema v1 · pii pii-v1

Severity

High

Discovered

—

Filed

Sep 7, 2010

To disclose

—

Affected

22,642

Confidence

98%
Full breach record for Aon →12 incidents on file

Aon Consulting, a business associate, prepared a request-for-proposal document for a covered entity's vision benefit program that mistakenly included PHI of 22,642 individuals. The document was publicly posted online for five days. Breached information located on a Network Server. PHI exposed included Social Security numbers, dates of birth, gender, zip codes, and vision plan enrollment information. The covered entity implemented multi-layer review controls and enforced its BAA with Aon; Aon offered credit monitoring and identity theft insurance to affected individuals.

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

Sep 7, 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.Confirmed22,642 affectedView incident

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.