AccidentalEducationEducationMisconfigurationCustomer Data InvolvedEmployee Data InvolvedIdentity (basic)Government IDHealth (basic)Financial accountPIIMediumContained

American Councils for International Education

bd_fe8ed06ddf59691e · schema v1 · pii pii-v1

Severity

Medium

Discovered

Apr 28, 2021

Filed

Jun 1, 2021

To disclose

5 weeks

Affected · nationwide

550119 in this filing

Linked

5 filings

Confidence

66%

Full breach record for American Councils for International Education →2 incidents on file

American Councils for International Education disclosed that program finalists were inadvertently granted administrator-level view access to a database containing applicant records between April 21-28, 2021. The exposure affected 550 individuals, including 119 in Washington. Data accessed included education records, medical records, government IDs, and bank account numbers. American Councils terminated access, conducted an investigation, revised user profiles, and offered credit monitoring.

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Washington clock⏱ WA AG >30d5 weeks discovery → filing

⚠ unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Incident timeline

undetected · 7 days

discovery → filing · 5 weeks / 34 days

Apr 21, 2021

Begins

Apr 28, 2021

Discovered

Jun 1, 2021

Filed

vs. sector median

2 wks faster

This filing is one of 5 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (4) · sorted by filing gap

Indiana State AGbd_4ce5e4c7799099972021-06-01Verified
Massachusetts State AGbd_61726bc6158987f32021-06-01Verified
Montana State AGbd_b5cf9c61318ab9c12021-06-01Candidate
New Hampshire State AGbd_f0b3045a5ecb0c442021-06-01Verified

Name: COZEN O'CONNOR
norm: cozen o connor

Name: American Councils for International Education
norm: american councils for international education
Industry: Educationllm

Discovered: Apr 28, 2021
Breach occurred: Apr 21, 2021 – Apr 28, 2021
Undetected for: 7 daysoccurrence → discovery
Materiality determined: —
Notification sent: May 18, 2021
Affected individuals: 550state + nationwide
Data types: Identity (basic)Government IDHealth (basic)Financial accountPII
Data elements: Medical information
Attack vector: Misconfiguration
MITRE ATT&CK: T1078 Valid Accounts
Threat actor: Internal
Regulator citations: Notified Washington State Office of the Attorney General
Initial access: valid_credentials

During the incident: Terminated all access to the Application Information System (AIS) Forms database
Conducted an internal investigation as to the extent of access and the possible causes for the data exposure
Revising user profiles so that user access is the default access provided within the AIS Forms database
Ensuring that applicants, finalists and participants cannot be given administrator-level access
Conducting refresher training for all American Councils personnel who administer the database
Offering identity protection and credit monitoring services to those whose social security number or bank account number was affected
Changes made: Revising user profiles so that user access is the default access provided within the AIS Forms database
Ensuring that applicants, finalists and participants cannot be given administrator-level access
Conducting refresher training for all American Councils personnel who administer the database
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 5 weeks(34 days from discovery to filing)
Compliance flags: WA AG >30d
Discovery-date grounding: unattributedNo provenance was recorded for this discovery date and it matches no other date on the record. It may be correct, but it is not independently grounded.

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 5 filings · 5 states

View merged incident ↗

Indiana State AGJun 1 · first

Massachusetts State AGJun 1 · first

Montana State AGJun 1 · first

New Hampshire State AGJun 1 · first

Washington State AGJun 1 · first · 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://agportal-s3bucket.s3.amazonaws.com/databreach/BreachM10474.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Jun 1, 2021
Raw hash: 4848c7a89e9da60df1306329c497716417a6069fc05b49199adad336a366c9cd

Linked disclosures

Regulatory filings (4) · sorted by filing gap

Reporting entityCOZEN O'CONNOR

Victim entityAmerican Councils for International Education

Incidentdiscovered Apr 28, 2021

Stated responseTerminated all access to the Application Information System (AIS) Forms database

ComplianceWA AG >30d

Extraction provenanceno artifact recorded

Source provenanceagportal-s3bucket.s3.amazonaws.com