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Leak SiteHHS OCRState AGConfirmed14 filings · 9 statesLifecycle stage 2 of 3: ConfirmedUnverified claimConfirmedEnforceddispossessorhigh sensitivity
Merged incident · 14 filings

Aon — December 2020 breach

Clustered 14 filings across 10 jurisdictions · filing window May 26, 2022 → Jul 3, 2022. View entity profile → Other incidents for this victim →

⚠ 1 cross-filing discrepancy →Merge100%

Determination

Confirmed

Members

14 filings

States

9

Affected · reported

153,784

First → last filing

May 26, 2022 → Jul 3, 2022

Merge confidence

100%

incident inc_a0be743bccfb4eae · merged by human · confidence 100%

Confirmed breach. Merged as one breach: 13 regulatory filings and 1 unverified claim. The filings describe unauthorized access. Intrusion Dec 29, 2020–Mar 1, 2022, discovered Feb 25, 2022 — the first regulatory filing landed 90 days later (flagged late). 153,784 individuals reported across the linked filings. Data reported: Government ID, PHI, Health (basic), and 2 more. Notifications rolled out on a 38-day schedule across 13 filings beginning May 26, 2022. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Supplemental
Notification delay
90days

Discovered → first regulatory filing

Discovery variance
0days

Range of discovered_at dates across filings

Leak precedence
Noneclaim trailed by 38d

Days between the first leak-site claim and the first regulatory filing. Positive = the claim came first (public exposure before disclosure). Negative = the claim trailed the filing, so there was no pre-disclosure leak. Counts regulatory filings only — press coverage is not a regulatory disclosure.

Filing span
38days

Time between earliest and latest filing

Not recorded for this incident

Materiality delta · SEC filing delay — no SEC 8-K in this cluster.

Regulatory clocksOregon✗ OR AG >45dCalifornia✗ CA 60-day late · 91dMaine✗ ME AG >90d · 119dWashington⏱ WA AG >30dHIPAA✓ HHS notifiedMassachusetts✓ MA credit monitoring dueFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Dec 29, 2020breach begins
Feb 25, 2022discovered
notification delay · 90 days
May 26, 2022first filing
Jul 1, 2022most recent filing

Dashed segments are unestablished, not zero — they fill in as filings merge into this incident.

Member cascade — every filing about this breach

  1. MAY 26HHS OCRHHS OCR noticefirst filing · states nationwide total 129,682day 0
  2. MAY 26OR AGOR AG noticestates nationwide total 31,799day 0
  3. MAY 26CA AGCA AG noticeno count statedday 0
  4. MAY 26ME AGME AG noticestates nationwide total 31,799day 0
  5. MAY 26WA AGWA AG notice3,328 WA residentsday 0
  6. MAY 26MT AGMT AG notice302 MT residentsday 0
  7. MAY 26MA AGMA AG notice648 MA residentsday 0
  8. MAY 27IN AGIN AG noticestates nationwide total 31,799+1d
  9. MAY 31NH AGNH AG notice233 NH residents+5d
  10. JUN 13NH AGNH AG notice34 NH residents+18d
  11. JUN 13MT AGMT AG notice250 MT residents+18d
  12. JUN 24ME AGME AG noticestates nationwide total 145,889+29d
  13. JUL 1ME AGME AG noticestates nationwide total 153,784+36d
  14. JUL 3Leak sitedispossessor postmost recent · attacker claim · unverified+38d
  15. Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window
Dec 29, 2020 – Mar 1, 2022
OR AG
Discovered
Feb 25, 2022· 423d undetected
OR AG + CA AG + ME AG +3
Data types
Health (basic) · Identity (basic) · Government ID · PHI · PII
HHS OCR + WA AG + CA AG +4
Attack vector
Unauthorized Access
HHS OCR

Each fact cites the member filing that establishes it; when filings conflict, every value shows with its source.

Count reconciliation

per-state reported counts

Nationwide (stated in a filing)

153,784

Sum of filed state slices

8,047· 5.2% of stated

95% of the stated total lives in states whose filings carry no count — the dashed share shrinks as filings land.

US153,784
WA3,328
IN3,080
MA648
ME456
MT302
NH233

State AGs report only their own residents; teal bars show each state's reported slice. The gray US row is the nationwide total reported in a linked filing.

Evidence ladder — rungs this incident occupies

Leak-site claim1 member

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

No press coverage linked yet.

State AG / regulator filing13 members

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

No SEC filing or victim statement yet.

Merge provenance

Method
human
Confidence
1.00 · above the 0.85 auto-merge floor
Reviewed
operator-reviewed Aug 22, 2026 · at least one link edge was human-adjudicated
Audit
Every link edge records its method, confidence and model + prompt versions (100% is the strongest edge).

Merges are reversible — a wrong link can be detached with its audit trail intact. How merging works.

Filing velocity

Spread

38 days

Cadence

~1 / 2.9d

vs. multi-state median

4.8× slower

About this clustering

DisclosureLens links filings into incidents through layered matchers: deterministic rules (same source document, multistate filings of one breach, tight-window same-victim pairs), a weighted-similarity scorer for cross-source candidates, and an operator review queue for everything uncertain. Each link records its own method and confidence — shown per filing in the timeline below. The system defaults to NOT merging when uncertain, because a false merge (collapsing two unrelated breaches) is more harmful than a false split (showing related filings separately); uncertain pairs route to human review instead of auto-merging. This page states only what the linked filings agree on; each filing's own account stays on its own record, linked from the timeline below.

The weekly clock on records like this one

The Disclosure Clock is a weekly briefing on what landed in the disclosure record, and the gap between the criminals' post and the regulator's filing — measured on the whole record, with the method shown.

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