Complete Chiropractic & Bodywork Therapies in Michigan is notifying 4,082 patients after discovering that malware had been injected into their system in November, 2015. Here is there notification posted to their web site today:
On March 19, 2016, Complete Chiropractic & Bodywork Therapies (“CCBT” or “we”) learned that CCBT’s server was accessed by unauthorized users – despite all of the IT safeguards that CCBT maintains. The affected server contained patient treatment and billing information, in addition to our encrypted electronic medical record data with information such as name, date of birth, address, social security number, and health/diagnosis information. This information is protected under both the federal Health Insurance Portability and Accountability Act (“HIPAA”) and Michigan law. However, there is no indication that this information was actually taken or inappropriately used – only that there was an opportunity for the same.
By way of background, upon discovering a server malfunction, CCBT immediately secured the server by disconnecting it from the Internet, changed all workstation and vendor passwords, and added additional IT security safeguards (e.g., an additional external firewall to monitor incoming and outgoing traffic). CCBT then engaged IT forensic experts to investigate the incident. The experts determined that the likely cause was a malware infection of a type that typically scans for login and password information and that the first unauthorized access was on November 19, 2015.
Again, although our investigation of the incident revealed that CCBT’s server was accessed by unauthorized users (i.e., the malware), we found no indication that patient protected health information was actually taken or inappropriately used. We hope that the information contained on the server will not be used for identity theft. However, due to the nature of the information involved, it is possible. Out of an abundance of caution, we notified all affected patients, offered them one-year of free identity theft protection through LifeLock, and provided them with recommended actions they can take to protect their information from identity theft. For example, we recommend that any affected patients obtain their credit reports from one or more of the major credit reporting agencies, and monitoring financial and bank accounts for unauthorized activity.
CCBT deeply regrets that this incident occurred. We are taking this matter very seriously and are working hard to make sure this does not happen again. CCBT hired new IT professionals who come highly recommended based on their HIPAA compliance experience. With the guidance of our new IT professionals, we are adding to the IT safeguards that CCBT already maintained.
If you have any questions or require additional assistance about this incident, please do not hesitate to contact CCBT at (800) 426-0580.