On February 11, Kentucky Counseling Center notified HHS of a breach impacting 16,440 patients. Using HHS’s coding system to report, the incident was reported as a case of unauthorized access/disclosure involving EMR.
But on their site, KCC makes clear that they suspect a former employee of taking a list of patient information. The full notification appears below, but to be honest, I find the incident a bit puzzling. Of note, they explain:
On January 4, 2019, a former staff member reported receiving an email containing a link to a list of Kentucky Counseling Center KCC patients. Based on KCC’s investigation to date, we believe a staff member took the list without authorization from our computer system on December 6, 2018. We believe that same individual used an anonymous Internet file sharing service to email the list to the former KCC staff member who then reported it to KCC. The individual we believe to be responsible for the email is no longer working with KCC.
While we do not believe the individual took the list to cause harm to individuals on the list, we wanted to make patients aware of these circumstances out of an abundance of caution.
So a then-current employee may have exfiltrated a list in excess of their authorization and then uploaded the list somewhere and sent a link to a former employee? Why? What do they suspect the former employee was going to do with that information? And has the now-former but then-current employee been charged criminally with theft of this information? HIPAA has criminal provisions. Are they being applied here?
Read the whole notification and see what you think. DataBreaches.net has sent an email inquiry to KCC and will update this post if additional information is received.Kentucky Counseling Center