San Juan Regional Medical Center updates its breach disclosure

On June 17, 2021, this site noted a breach involving San Juan Regional Medical Center that had been reported to HHS and posted on the entity’s web site.  According to their notification on June 4, the breach occurred September 7-8, 2020, and the threat actor exfiltrated data at that time. In April, 2021, they allegedly discovered that protected health information was involved, and they subsequently notified 68,792 patients. So nine months after the attack, patients were first being notified.

The center’s June 4, 2021 statement has now been replaced, it appears, with a statement of October 7, 2021. That statement replaces the statement of discovery in April, 2021, with a statement that “Following a thorough manual document review of the files that were removed, we discovered on July 13, 2021 that the impacted files contained the personal and protected health information of certain patients who are now being notified.”

So it seems that in July, they discovered additional patients who needed to be notified, and those patients were first notified recently.

It is now more than one year since the medical center was attacked and data exfiltrated and patients are first being notified. SJRMC addresses the gap this way:

SJRMC previously identified and notified patients of this incident. The manual document review of the impacted files was extensive and required significant time to complete. As a result, SJRMC provided two rounds of notification – one in June and one in September.

SJRMC takes this incident and security of personal information very seriously. Cybersecurity threats continue to evolve and as a result, SJRMC has taken additional steps to secure its network and improve internal procedures to identify and remediate future threats. SJRMC continues to assess and update its internal policies and procedures in order to minimize the risk of a similar incident in the future.

Will their explanation suffice to avert any monetary penalties by state or federal regulators or lawsuit by patients? That all remains to be seen. The incident is still open on HHS’s public breach tool, and the number impacted has not been updated there, so we do not know the current estimate of the number impacted.

The center stated that although this was a malware attack, it was not a ransomware incident. has never seen any evidence of any patient data from this incident on any of the dozens of ransomware leak sites created by threat actors or leak sites that are not necessarily confined to ransomware incidents.

So what happened here? The center may not be aware of any misuse, but unless one thinks the hack and exfiltration were for fun, patients whose data has been exfiltrated continue to have cause to be concerned.

Corrected at 12:32 pm to reflect that the the medical center was clear that this was not a ransomware attack although malware was used to exfiltrate data.

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