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Confirmed2 filings · 1 stateUnverified claimConfirmedEnforcedhigh sensitivity

Merged incident · 2 filings

The Guidance Center, Inc. — March 2019 breach

Clustered 2 filings across 1 jurisdiction · filing window Oct 28, 2019 → Oct 30, 2019. View entity profile → Other incidents for this victim →

⚠ 1 cross-filing discrepancy →Merge87%

Determination

Confirmed

Members

2 filings

States

Affected · reported

1,235

First → last filing

Oct 28, 2019 → Oct 30, 2019

Merge confidence

87%

incident inc_b4fb10f4186c473f · merged by deterministic · confidence 87%

Confirmed breach. Merged as one breach: 2 regulatory filings. The filings describe misuse of authorized access. Intrusion Mar 15, 2019–Apr 1, 2019, discovered Mar 25, 2019 — the first regulatory filing landed 217 days later (flagged late). 1,235 individuals reported across the linked filings. Data reported: Government ID, Identity (basic), Health (basic), and 1 more. Each member filing remains the legal record for its jurisdiction.

Litigation Timing

Notification delay

217days

Discovered → first regulatory filing

Filing span

2days

Time between earliest and latest filing

Not recorded for this incident

Discovery variance · Leak precedence · Materiality delta · SEC filing delay — no leak-site claim in this cluster; no SEC 8-K in this cluster; needs two dated filings.

Regulatory clocksCalifornia✗ CA 60-day late · 217dHIPAA✓ HHS notifiedFull clock table in Litigation Timeline

Sensitive data

identity_government

Incident timeline

Mar 15, 2019breach begins

Mar 25, 2019discovered

notification delay · 217 days

Oct 28, 2019first filing

Oct 30, 2019most recent filing

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

Member cascade — every filing about this breach

OCT 28HHS OCRHHS OCR noticefirst filing · states nationwide total 1,189operator-confirmedday 0
OCT 30CA AGCA AG noticemost recent · 1,235 CA residentsoperator-confirmed+2d
Watching for additional filings — new sources merge into this incident automatically.

Roll-up facts — reconciled across members

Breach window: Mar 15, 2019 – Apr 1, 2019
Discovered: Mar 25, 2019· 10d undetected
Data types: Health (basic) · Identity (basic) · Government ID · PHI
Attack vector: Unauthorized Access

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

Evidence ladder — rungs this incident occupies

Leak-site claim

No leak-site claim on record for this incident.

Press / market report

No press coverage linked yet.

State AG / regulator filing2 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: deterministic
Confidence: 0.87 · above the 0.85 auto-merge floor
Reviewed: operator-reviewed Jun 13, 2026 · at least one link edge was human-adjudicated
Audit: Every link edge records its method, confidence and model + prompt versions (87% is the strongest edge).

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

Filing velocity

Spread

2 days

vs. multi-state median

4.0× faster

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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