News & Analysis as of

Data Breach Risk Assessment Enforcement Actions

Saul Ewing LLP

HHS OCR Continues Active HIPAA Enforcement with Three New Settlements

Saul Ewing LLP on

In the past several weeks, the U.S. Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR") has announced settlements with three health care organizations — Comstar, LLC ("Comstar"); Guam Memorial...more

ArentFox Schiff

OCR’s Risk Analysis Initiative: Lessons From Recent HIPAA Enforcement Actions

ArentFox Schiff on

Health care organizations are under pressure to shore up their cybersecurity response efforts. Much of this pressure is coming from the US Department of Health and Human Services Office for Civil Rights (OCR), which has made...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

2025 Enforcement Trends: Risk Analysis Failures at the Center of HHS’s Multimillion-Dollar HIPAA Penalties

In the first five months of 2025, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) announced it had entered into ten Health Insurance Portability and Accountability Act (HIPAA) resolution...more

Ankura

HIPAA Security Risk Analysis – How should regulated entities prepare for the Office for Civil Rights (OCR) Risk Analysis Audit...

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Following the Office for Civil Rights (OCR) recent publication of four settlements as part of a new Risk Analysis Audit Initiative. We explore the current regulatory language for Risk Analysis, the proposed language for Risk...more

Sheppard Mullin Richter & Hampton LLP

Auto Insurer Settles With New York AG Over Insurance Application Platform Security Issues

The New York Attorney General recently entered into an assurance of discontinuance with Root Insurance Company following a 2021 data incident. According to the AG, the threat actors obtained people’s drivers’ license numbers...more

Arnall Golden Gregory LLP

OCR Announces Fifth Settlement Under Its Risk Analysis Initiative

Background - On March 21, 2025, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) announced a settlement with Health Fitness Corporation (“Health Fitness”), a company that provides wellness...more

Shook, Hardy & Bacon L.L.P.

OCR Enforcement Activity: Trends and Insights From a Limited Sample

Arecent report put the odds of an asteroid hitting the earth in December 2032 at 3.1%—which is 3,100 times more likely than an organization resolving an enforcement action with the U.S. Department of Health and Human...more

Carlton Fields

Cybersecurity May Be OCR’s New Year’s Resolution

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The U.S. Department of Health and Human Services Office for Civil Rights (OCR) appears to have made cybersecurity its New Year’s resolution. The first few weeks of 2025 have already brought with them proposed amendments to...more

Robinson+Cole Data Privacy + Security Insider

CT AG Settles Data Breach Case with Guardian Analytics

Connecticut Attorney General William Tong announced on October 21, 2024, that his office has settled a data breach case against Guardian Analytics, Inc. for $500,000. The data breach affected the personal information of...more

Nelson Mullins Riley & Scarborough LLP

And T-Mobile Makes Three: More Information Security Guidance for Telecommunications Carriers from the FCC

Close on the heels of its Consent Decrees with TracFone and AT&T, on September 27, 2024, the Enforcement Bureau of the Federal Communications Commission (FCC) announced that it reached a Consent Decree with T-Mobile US, Inc....more

Health Care Compliance Association (HCCA)

Employees’ Misdeeds, Lack of Risk Analysis Cost NY Hospital $4.75M; OCR Issues Warning

Although the HHS Office for Civil Rights (OCR) described its recent $4.75 million agreement with a Bronx, New York, hospital as settling a “malicious insider cybersecurity investigation,” the agency considered a total of 11...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - May 6th - 9th, San Antonio, TX

Ideal for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy offers practitioners a deeper understanding of effective compliance management in a healthcare setting. The...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - October 16th - 19th, San Francisco, CA

Designed for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy is ideal for practitioners who want a deeper understanding of effective compliance management in a...more

Butler Snow LLP

Cybersecurity: What Businesses Need to Know

Butler Snow LLP on

Cybersecurity is a top concern for all industries, particularly for the pharmaceutical and medical device industries. These industries hold some of the most sensitive data and highly valuable technology, making them prime...more

Ankura

How Cybersecurity Protects Valuation: Considerations for Private Equity in the Deal Lifecycle

Ankura on

Cybersecurity risk applies to businesses of all sizes and across all industries – it is a risk that cannot be ignored. In particular, cybersecurity risk can no longer be ignored in the deal lifecycle...more

Health Care Compliance Association (HCCA)

[Virtual Event] Hawaii Regional Healthcare Compliance Conference - October 7th, 7:55 am - 4:00 pm HST

Our Virtual Regional Healthcare Compliance Conferences provide updates on the latest news in regulatory requirement, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask...more

White & Case LLP

Cybersecurity Enforcement: New York Department of Financial Services issues first penalty under Cybersecurity Regulation

White & Case LLP on

Consistent with its increasing activity in the cybersecurity enforcement space, in March 2021, the NYDFS issued its first penalty under the Cybersecurity Regulation. This client alert explores the settlement and offers...more

Faegre Drinker Biddle & Reath LLP

New York Department of Financial Services Announces $1.5 Million Settlement of Second Cybersecurity Enforcement Action

On March 3, 2021, the New York State Department of Financial Services (NYDFS) announced a settlement with Residential Mortgage Services, Inc. (RMS) for $1.5 million in connection with its violation of the NYDFS Cybersecurity...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - November 2nd - 5th, Nashville, TN

Dive into a broad spectrum of topics affecting healthcare organizations. Explore the latest laws, regulations, and developments to help you effectively manage your organization’s privacy compliance program. Our Academies are...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - February 27th - 28th, Anchorage, AK

This two-day Regional Compliance and Ethics Conferences provide attendees with a forum to interact with local compliance professionals, share information about your compliance successes and challenges, and create educational...more

Orrick, Herrington & Sutcliffe LLP

A Survival Guide for GDPR Enforcement Actions from a German Perspective – How to Assess and Mitigate Fines for GDPR Violations

Since the first enforcement actions have been initiated, some with significant fines, many companies may find themselves somewhat at a loss as they may not fully know how to assess the risks involved and how to react should...more

Robinson+Cole Data Privacy + Security Insider

Jackson Health System Fined by OCR for $2.15 Million

The Office for Civil Rights (OCR) announced on October 23, 2019, that Jackson Health System (“Jackson”), a not for profit hospital system comprised of six hospitals, urgent care centers, nursing facilities and primary care...more

Barnea Jaffa Lande & Co.

When the Privacy Watchdogs Bare Their Teeth

July 2019 brought an escalation in the enforcement of privacy infringements by companies around the world. The trend began with a press release published on July 8, 2019, of a fine in the approximate amount of GBP 183 million...more

Womble Bond Dickinson

New York: Reasonable InfoSec or Not Reasonable InfoSec? That Is The Question.

Womble Bond Dickinson on

Last week, the New York State Senate, at the request of the state attorney general, passed the “Stop Hacks and Improve Electronic Data Security Act” (the “Shield” Act). The bill is currently working its way through the New...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Investigative Report on Cybersecurity Emphasizes Internal Controls

On October 16, 2018, the Securities and Exchange Commission (SEC) issued a Report of Investigation (Report) detailing an investigation by the SEC’s Enforcement Division into the internal accounting controls of nine issuers...more

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