HackingHealthcareProfessional ServicesHealthcareStolen CredentialsSupply Chain (3P Vendor)Data ExfiltratedCustomer Data InvolvedIdentity (basic)Government IDFinancial accountMediumContained

Compass Health, Inc.

bd_f74ca9da77f4b44b · schema v1 · pii pii-v1

Severity

Medium

Discovered

Mar 20, 2020

Filed

May 27, 2020

To disclose

10 weeks

Affected

1state residents only

Linked

3 filings

Confidence

66%

Full breach record for Compass Health, Inc. →

Compass Health, Inc. d/b/a Compass Health Network notified the NH Attorney General of a third-party vendor breach involving PaperlessPay Corporation. Unauthorized access to PaperlessPay's SQL server occurred on Feb 18, 2020, via stolen credentials. Data potentially exposed includes employee names, addresses, SSNs, and bank account numbers. One NH resident affected. Compass provided credit monitoring via Experian.

J jump to incidentP pin to compareR raw source

Incident timeline

undetected · 31 days

discovery → filing · 10 weeks / 68 days

Feb 18, 2020

Begins

Mar 20, 2020

Discovered

May 27, 2020

Filed

vs. sector median

3 wks faster

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

Part of PaperlessPay Corporation supply-chain incident (2020) — a supply-chain cascade affecting multiple organizations.View cascade →

Linked disclosures

Why this link?

Regulatory filings (2) · sorted by filing gap

Massachusetts State AGbd_bce67c6ae78252782020-05-26 · +1dVerified
Montana State AGbd_e2ecd01b0f7f3f292020-05-26 · +1dCandidate

Name: Polsinelli PC
norm: polsinelli

Name: Compass Health, Inc.
norm: compass health
Also named: Compass Health, Inc.dba oflegal entity
Compass Health Networkdba oftrade name
Industry: HealthcarellmProfessional Servicesllm

Discovered: Mar 20, 2020
Breach occurred: Feb 18, 2020
Undetected for: 31 daysoccurrence → discovery
Materiality determined: —
Notification sent: May 26, 2020
Affected individuals: 1state-resident count only
Data types: Identity (basic)Government IDFinancial account
Data elements: Social Security number
Attack vector: Third-Party / Supply Chain
MITRE ATT&CK: T1195 Supply Chain CompromiseT1078 Valid AccountsT1041 Exfiltration Over C2 Channel
Threat actor: ExternalFinancial
Regulator citations: Notified Attorney General Gordon J. MacDonald of New Hampshire pursuant to N.H. Rev. Stat. § 359-C:20
Initial access: valid_credentials

During the incident: Promptly investigated the incident to determine what, if any, personal information a third party might have acquired
Providing complimentary identity theft protection services to the impacted individual through Experian
Notifying potentially impacted employees
Notified the Attorney General of New Hampshire
Changes made: Arranged for complimentary one-year membership of Experian IdentityWorks Credit 3B for all potentially impacted employees
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 10 weeks(68 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 ↗

Massachusetts State AGMay 26 · first

Montana State AGMay 26 · first

New Hampshire State AG+1d · this page

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/compass-health-dba-compass-health-network-20200527.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: May 27, 2020
Raw hash: 226ed1a945d9577d6fd7771b33c6b091b1cb34bd6de9dc57dab9101d8a6ad5fc

Linked disclosures

Regulatory filings (2) · sorted by filing gap

Reporting entityPolsinelli PC

Victim entityCompass Health, Inc.

Incidentdiscovered Mar 20, 2020

Stated responsePromptly investigated the incident to determine what, if any, personal information a third party might have acquired

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov