Let’s start with their notice of the incident:
Chadron Community Hospital and Health Services takes our obligation to protect our patients’ personal health information seriously. Regrettably, this notice concerns some of that information.
On January 3, 2017, we learned that one of our staff members had accessed patient medical records outside of the employee’s job duties. We immediately began an investigation and confirmed that between September 2011 and November 2016 the employee viewed some patients’ electronic medical records and may have accessed demographic information, such as name, address and date of birth; clinical information, such as diagnosis, orders, provider notes and test results; and certain financial information, such as insurance information. We do not believe the former employee accessed any Social Security numbers.
We are sending letters to all affected patients and posting this notice. To learn whether your information was included in the breach or to ask questions, please call toll free at 1-844-840-8231, Monday through Friday between 9:00 a.m. and 5:00 p.m. Mountain Time, or you may email us at [email protected]
Whenever personal information is accessed without authorization, it is advisable that you take measures to help prevent and detect any potential misuse of your information. We encourage patients who believe they might have been affected to closely monitor financial accounts for unusual activity and consider requesting a free credit report from one of three major credit bureaus. To order your free credit report, please contact one of the companies below:
• Equifax 1-800-525-6285 www.equifax.com
• Experian 1-888-397-3742 www.experian.com
• TransUnion 1-800-680-7289 www.transunion.com
If you find suspicious activity on your credit reports, or have reason to believe your information is being misused, call your local law enforcement and file a police report as soon as possible. You also should file a complaint with the FTC at www.ftc.gov/idtheft or at 1-877-ID-THEFT (877-438-4338). We value patient privacy and deeply regret any inconvenience this may have caused our patients and their families. To help prevent something like this from happening in the future, we are reviewing our privacy policies and practices and reinforcing education with all staff regarding the importance of maintaining the confidentiality of our patients’ information and appropriate care-related access to patient records.
According to HHS’s public breach tool, the incident was reported to HHS on February 19 and affected 702 patients.
What’s not obvious to me from their notice is whether the hospital’s response to the incident is sufficient. Was the employee accessing the files out of curiosity or were the data acquired and intended for misuse? If the latter, simply reinforcing employee education is not going to prevent a recurrence. Where are the technical/software safeguards that might have prevented this or at least caught it a lot earlier? Hopefully, that’s what they are referring to when they say they are reviewing their practices.