UC San Diego Health

The covered entity (CE), UC San Diego Health, reported that its business associate (BA) impermissibly used analytics tools on its websites that captured and transmitted the protected health information (PHI) of 22,971 individuals to its third-party service providers without a valid business associate agreement. The PHI involved included names, dates of birth, addresses, email addresses, IP addresses, and health insurance information. The CE notified HHS, the affected individuals, the media, and provided substitute notice. In its mitigation efforts, the CE terminated its business relationship with the BA and implemented new policies and procedures and retrained workforce members to better protect PHI.