CA: Notice to Individuals Regarding Privacy Incident Involving Capitol Administrators, Inc.
Notice how they do not tell us when the phishing attack occurred – only when they concluded their investigation of it. So when was this attack, and when was it actually discovered for purposes of the 60-day clock? And how many people are being notified? From their substitute notice on their web site:
Capitol Administrators, Inc. (“Capitol”) understands the importance of protecting the information it maintains. This notice relates to information of some members of the group health plans it provides claims processing and related services to.
Capitol is a third party administrator hired by companies to provide benefits administration. To accomplish this function, our clients, medical providers and others provide us with data about Plan participants, including certain types of personal and medical information.
On March 30, 2018, Capitol learned through a forensic investigation of a phishing email incident that certain emails and attachments had been accessed by an unauthorized person. Upon first learning of the phishing incident, Capitol took immediate steps to secure the account, conduct an internal investigation, and enhance the security of its system. Capitol also engaged a leading cyber security firm to perform an investigation. That investigation determined that an unauthorized individual accessed certain emails and attachments in a small number of Capitol employees’ email accounts. While the investigation could not determine if the attachments to the emails had been opened by the unauthorized person that possibility could not be ruled out. The emails and attachments contained member information provided to Capitol in connection with their group health plans. This information included names and some or all of the following: Social Security numbers, medical information, and/or health insurance numbers.
Out of an abundance of caution, Capitol began notifying the potentially affected individuals on May 11, 2018 and we have established a dedicated call center to answer any questions. If you believe you may be affected by this incident but did not receive a letter by Monday, May 28, 2018, please call 1-833-219-9090, Monday-Friday between 9:00 a.m. and 6:00 p.m., Eastern Time.
Capitol regrets that this incident occurred. In addition to providing notice of the incident, Capitol has taken various steps to enhance its existing network and email security, including implementing multi-factor authentication and upgrading its security center, as well as providing education and training to its employees to help prevent a similar incident from happening in the future.