The covered entity's (CE) staff member disclosed an unencrypted Microsoft Excel graph to a non-covered entity physician who re-disclosed it to a medical education organization to be used in a presentation. In addition, the medical education organization posted the presentation slides on its website. The graph contained the protected health information (PHI) of 569 individuals and included names, telephone numbers, social security numbers, ages, cities and states of residence, medical record numbers, and clinical information. Upon discovery of the breach, the CE ensured that the information was removed from the website and deleted, sanctioned the workforce member responsible, and retrained its workforce on the use of a data loss prevention tool and the risks of embedded PHI. As a result of OCR's investigation, the CE provided OCR with evidence of its technical safeguards and security awareness initiatives and provided assurance that it implemented the corrective action listed above.
