Notice of Data Security Incident
Nemadji provides patient eligibility and billing services for healthcare facilities. On March 28, 2019, Nemadji identified unusual activity in an employee’s email account. We immediately launched an investigation, with the assistance of a third-party computer forensics expert to determine what may have happened and what information may have been affected. Our investigation determined that an unknown individual had access to the employee’s email account for several hours on March 28, 2019 due to the employee falling victim to a phishing email. While almost all of the information in the email account was encrypted at the time of the incident, the encryption keys or similar variations were included in the email account. Therefore, we reviewed the email account to identify what personal information was stored within the account and to whom that information was related. On June 5, 2019, we identified the first instance of personal information that may have been accessible as a result of this incident, and Nemadji began providing notice of the incident to its healthcare facility business partners.
What Information Was Involved?
The personal information present in the email account at the time of the incident varied by individual but may have included first and last names and one or more of the following data elements: address, admission/discharge date, claim number, aid category, date of birth, Social Security number, diagnosis code, group name, group number, insurance information, medical record number, other encounter identifier, patient account number, Medicaid/Medicare/other identification number, and subscriber name.
What Is Nemadji Doing?
Information privacy and security are among our highest priorities. Nemadji has strict security measures in place to protect information in our care. Upon discovering this incident, we quickly took steps to confirm the security of our systems, including our employee email accounts. We reviewed existing security policies and implemented additional measures to further protect information, including enhanced email security and employee training. We also reported this incident to the Federal Bureau of Investigation and notified necessary state and federal regulators. In an abundance of caution, we are also notifying potentially impacted individuals so that they may take further steps to best protect their information, should they feel it is appropriate to do so. Although we are unaware of any actual or attempted misuse of information as a result of this incident, we are offering potentially impacted individuals access to credit monitoring and identity protection services.
What You Can Do?
Nemadji has established a dedicated assistance line for individuals seeking additional information regarding this incident. Individuals may call 1-800-491-4740, 8:00 a.m. to 5:30 p.m. PT, Monday through Friday; or email email@example.com with questions or if they would like additional information. Below is additional information about what individuals can do to protect their information:
Monitor Your Accounts
Nemadji encourages potentially impacted individuals to remain vigilant against incidents of identity theft and fraud and to review account statements, credit reports, and explanation of benefits forms for suspicious activity. Under U.S. law, individuals with credit reports are entitled to one free credit report annually from each of the three major credit reporting bureaus. To order your free credit report, visit www.annualcreditreport.com or call, toll-free, 1-877-322-8228.
You have the right to place a “security freeze” on your credit report, which will prohibit a consumer reporting agency from releasing information in your credit report without your express authorization. The security freeze is designed to prevent credit, loans, and services from being approved in your name without your consent. However, you should be aware that using a security freeze to take control over who gets access to the personal and financial information in your credit report may delay, interfere with, or prohibit the timely approval of any subsequent request or application you make regarding a new loan, credit, mortgage, or any other account involving the extension of credit. Pursuant to federal law, you cannot be charged to place or lift a security freeze on your credit report. Should you wish to place a security freeze, please contact the major consumer reporting agencies listed below:
|P.O. Box 9554|
Allen, TX 75013
|P.O. Box 2000|
Chester, PA 19016
|P.O. Box 105788|
Atlanta, GA 30348
|Experian Credit Freeze||TransUnion Credit Freeze||Equifax Credit Freeze|
In order to request a security freeze, you will need to provide the following information:
- Your full name (including middle initial as well as Jr., Sr., II, III, etc.);
- Social Security number;
- Date of birth;
- If you have moved in the past five (5) years, provide the addresses where you have lived over the prior five years;
- Proof of current address, such as a current utility bill or telephone bill;
- A legible photocopy of a government-issued identification card (state driver’s license or ID card, military identification, etc.);
- If you are a victim of identity theft, include a copy of either the police report, investigative report, or complaint to a law enforcement agency concerning identity theft.
As an alternative to a security freeze, you have the right to place an initial or extended “fraud alert” on your file at no cost. An initial fraud alert is a 1-year alert that is placed on a consumer’s credit file. Upon seeing a fraud alert display on a consumer’s credit file, a business is required to take steps to verify the consumer’s identity before extending new credit. If you are a victim of identity theft, you are entitled to an extended fraud alert, which is a fraud alert lasting seven years. Should you wish to place a fraud alert, please contact any one of the agencies listed below:
|P.O. Box 2002|
Allen, TX 75013
|P.O. Box 2000|
Chester, PA 19016
|P.O. Box 105069|
Atlanta, GA 30348
|Experian Fraud Center||TransUnion Fraud Center||Equifax Fraud Center|
You can further educate yourself regarding identity theft, fraud alerts, security freezes, and the steps you can take to protect yourself, by contacting the consumer reporting agencies, the Federal Trade Commission, or your state Attorney General.
The Federal Trade Commission can be reached at: 600 Pennsylvania Avenue NW, Washington, DC 20580; www.identitytheft.gov; 1-877-ID-THEFT (1-877-438-4338); TTY: 1-866-653-4261. The Federal Trade Commission also encourages those who discover that their information has been misused to file a complaint with them. You can obtain further information on how to file such a complaint by way of the contact information listed above. You have the right to file a police report if you ever experience identity theft or fraud. Please note that in order to file a report with law enforcement for identity theft, you will likely need to provide some proof that you have been a victim. Instances of known or suspected identity theft should also be reported to law enforcement and your state Attorney General. This notice has not been delayed by law enforcement.
For North Carolina Residents, the Attorney General can be contacted at 9001 Mail Service Center, Raleigh, NC 27699-9001, 1-877-566-7226 or 1-919-716-6400, www.ncdoj.gov.
For Maryland residents, the Attorney General can be contacted at 200 St. Paul Place, 16th Floor, Baltimore, MD 21202, 1-888-743-0023, www.oag.state.md.us.
For New Mexico residents, you have rights pursuant to the Fair Credit Reporting Act, such as the right to be told if information in your credit file has been used against you, the right to know what is in your credit file, the right to ask for your credit score, and the right to dispute incomplete or inaccurate information. Further, pursuant to the Fair Credit Reporting Act, the consumer reporting agencies must correct or delete inaccurate, incomplete, or unverifiable information; consumer reporting agencies may not report outdated negative information; access to your file is limited; you must give your consent for credit reports to be provided to employers; you may limit “prescreened” offers of credit and insurance you get based on information in your credit report; and you may seek damages from violators. You may have additional rights under the Fair Credit Reporting Act not summarized here. Identity theft victims and active duty military personnel have specific additional rights pursuant to the Fair Credit Reporting Act. We encourage you to review your rights pursuant to the Fair Credit Reporting Act by visiting www.consumerfinance.gov/f/201504_cfpb_summary_your-rights-under-fcra.pdf, or by writing Consumer Response Center, Room 130-A, Federal Trade Commission, 600 Pennsylvania Ave. N.W., Washington, D.C. 20580.
For Rhode Island Residents, the Rhode Island Attorney General can be reached at: 150 South Main Street, Providence, Rhode Island 02903, www.riag.ri.gov, 1-401-274-4400. Under Rhode Island law, you have the right to obtain any police report filed in regard to this incident.
This posting contains an important notice. If you cannot read this document, please call 1-800-491-4740 for translation help.
Posted Jul 8, 2019