The Guidance Center notifies 1,235 patients after discovering insider wrongdoing

What havoc and costs a rogue insider/employee can cause. Here’s another example — this one from a new disclosure by external counsel for The Guidance Center in Long Beach, California. The Guidance Center (TGC) provides comprehensive mental health treatment to disadvantaged youth and their families. In their lawyer’s words:

In late March of 2019, TGC detected unusual activity within its digital environment when certain files could not be located by TGC staff. TGC immediately launched an internal investigation and discovered that some files and backups had been deleted, and that a computer had been reconfigured to permit remote access. Soon thereafter, TGC determined that these activities were most likely conducted by a former employee. TGC’s attorney sent this former employee a cease-and-desist letter on March 30, 2019, soon after which malicious activity ceased. TGC also reported this matter to the Long Beach Police Department and FBI. As a result, TGC worked several weeks to restore and secure its systems, and ensure operations were maintained.

On April 19, 2019, TGC engaged a leading, independent digital forensics firm to conduct an investigation into this incident and to determine whether there had been unauthorized access to sensitive client and/or employee information. The firm found no evidence that sensitive information contained on TGC’s information systems was accessed or acquired without authorization. However, the firm found that the former employee gained unauthorized remote access to certain TGC email accounts. On August 15, 2019, TGC learned that these email accounts contained some sensitive information. TGC then worked diligently to identify up-to-date address information required to notify potentially impacted individuals. On October 28, 2019, TGC confirmed that the personal information of the above-referenced California residents may have accessed without authorization, and provided notification of the incident to the U.S. Department of Health and Human Services’ Office for Civil Rights (“OCR”), pursuant to the HIPAA Breach Notification Rule. TGC previously notified the California Department of Public Health.

TGC is offering those impacted 12 months of credit monitoring with TransUnion. Their letter does not explain what the (presumably now former) employee’s motivation might have been in accessing files and deleting backups. Not only is their notification to the state attorney general silent on that point, but their letter to affected patients, reproduced below, does not reveal that it was an employee who was the bad actor in this matter.

If you were a patient of TGC or any entity that was notifying you of a breach that involves your mental health treatment, would it matter to you whether this was an external hack by someone outside of the country compared to a rogue employee? Do you want to know something about *who* did this and why so you could evaluate your risk? I would.

The Guidance Center - California Attorney General Notification Letter
The Guidance Center - Sample Notification Letter (CA)

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