Breach filing
ArchivedUpstream RollCo, LLC: 748,678 individuals, Apr 2023.
Upstream RollCo, LLC reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 22 April 2023. The filing records the organisation as a healthcare provider in Alabama and lists 748,678 individuals affected, which makes it the 2nd largest of the 98 Alabama filings on the register and the 46th largest of the 746 filings submitted nationally in 2023. Among the 9 Alabama filings made in 2023 it ranks 1st.
Individuals affected
748,678
As reported to HHS
Modelled cost (IBM 2025)
$120M
Upper bound, method shown
Rank in AL
2nd
of 98 Alabama filings
Rank in 2023
46th
of 746 filings nationally
Section F.1 / The filing
As posted by HHS OCR
Every value below is the portal's own field for this filing, plus its rank within the register.
- Covered entity type
- Healthcare Provider
- Individuals affected
- 748,678
- Breach submission date
- 22 April 2023
- Submission year
- 2023
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Alabama (AL)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Alabama by size
- 2nd of 98
- Rank in 2023 nationally
- 46th of 746
- Alabama median filing
- 5,000 individuals
- Register id (derived)
- AL-20230422-upstream-rollco
Section F.2 / In context
Where this filing sits in Alabama and in 2023
OCR classifies the incident as a hacking or IT incident, with the breached information held in email. Hacking/IT Incident is the type recorded on 60 of the 98 Alabama filings (61%) and on 82% of all filings submitted in 2023. Email appears on 15% of Alabama filings.
No business associate is recorded on the filing; 29% of Alabama filings do involve one. At 748,678 individuals the breach is 150 times the Alabama median filing of 5,000 and 187 times the national median of 4,000 across all 7,884 filings. It is one of 801 filings of 100,000 or more individuals.
As of 28 August 2026 the case is listed in the HHS OCR breach portal archive. OCR's closing summary of the case is reproduced in full below.
Alabama's breach notification statute (Ala. Code 8-38-1 et seq.) requires notice to affected residents without unreasonable delay, no later than 45 days after determining a breach occurred. Its attorney general threshold: more than 1,000 Alabama residents. The HIPAA Breach Notification Rule ran alongside it: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery, which is the clock that put this filing on the portal.
Multiplying 748,678 individuals by IBM's $160 customer-PII cost per record (Cost of a Data Breach 2025, the figure the site's calculator uses) gives a modelled $120M; the 2026 edition's $192 gives $144M. Both are modelled estimates with the method shown, not costs disclosed by Upstream RollCo, LLC. Because the filing is above the roughly 100,000-record range in which the per-record figure is reliable, the result is an upper bound, not an estimate: fixed costs are spread across far more records at this scale.
Section F.3 / OCR closing summary
The portal's archived description, in full
Written by the Office for Civil Rights when the case was closed and reproduced verbatim from the HHS export.
The covered entity (CE), Upstream RollCo reported that multiple employees were the targets of an email phishing incident that affected the protected health information (PHI) of 748,678 individuals. The PHI involved included names, dates of birth, Social Security Numbers, physical addresses, claims information, diagnoses, and other treatment information. The CE notified HHS, affected individuals, the media, and posted substitute notice on its website. In response to the breach, the CE implemented additional administrative, technical, and security safeguards.
Section F.5 / Modelled cost
748,678 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$120M
748,678 x $160
IBM 2026 customer PII, $192 per record
$144M
748,678 x $192
Method: individuals affected, as reported by Upstream RollCo, LLC to HHS, multiplied by IBM's customer-PII cost per record (Cost of a Data Breach 2025 Figure 6 and the 2026 edition). No cost has been disclosed by the entity for this filing; the figure is a planning estimate, not a fact about the breach. IBM's per-record figures come from mid-volume breaches and IBM cautions against applying them to breaches involving millions of records; the site's per-record page explains where the multiplication holds and where it breaks down.
Context: IBM's average cost of a healthcare breach is $6.64M in the 2026 report ($7.42M in 2025); the global average across all sectors was $4.44M in 2025.
Cost per record: method and limits / Healthcare breach cost, IBM 2026
Section F.6 / Notification clock
Alabama statute and the HIPAA rule
State notification statute
Alabama: Ala. Code 8-38-1 et seq.
Alabama Data Breach Notification Act of 2018
- Notice to individuals
- Without unreasonable delay, no later than 45 days after determining a breach occurred
- Attorney general threshold
- More than 1,000 Alabama residents (Within the same 45-day window)
- Private right of action
- No: Enforcement is exclusive to the Alabama Attorney General
- Penalty
- Civil penalties up to $5,000 per day, capped at $500,000 per breach, as an unlawful trade practice
The HIPAA Breach Notification Rule runs alongside the state statute: notice to affected individuals and to HHS without unreasonable delay and no later than 60 days after discovery.
Section F.7 / Peer filings
Alabama filings closest in size
Neighbours by size rank among Alabama filings in 2023, topped up from other years where 2023 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Sutter Medical Foundation | Healthcare Provider | 943,434 | 17 Nov 2011 | |||
| Cardiovascular Associates | Healthcare Provider | 433,348 | 3 Feb 2023 | |||
| Sarrell Dental | Healthcare Provider | 363,617 | 12 Sep 2019 | |||
| Alabama Cardiovascular Group | Healthcare Provider | 280,534 | 2 Aug 2024 | |||
| Acadia Health, LLC d/b/a Just Kids Dental | Healthcare Provider | 129,463 | 27 Sep 2023 |
Index / Companion schedules
13 HHS breach register
→Hub: every filing, by state, year and entity.
04 Biggest breaches
→Mega-breaches with primary-source cost figures.
Industry / Healthcare
→IBM 2026: $6.64M average, 13 years at #1.
Regulation / HIPAA penalties
→OCR enforcement tiers and the 60-day rule.
11 50-state laws
→Deadline, AG threshold and penalties per state.
Cost / Per record
→Where the per-record model is reliable.
Provenance
Source: U.S. Department of Health and Human Services, Office for Civil Rights, Breach Portal (breaches affecting 500 or more individuals), retrieved 2026-08-28. Public domain. Individuals affected and dates as reported by the covered entity.
Portal: ocrportal.hhs.gov breach report. Statutory basis: HITECH Act section 13402(e)(4): the Secretary must post a list of breaches of unsecured protected health information affecting 500 or more individuals. Breaches affecting fewer than 500 individuals are reported to OCR annually and are not posted, so they are not on this register. Status wording follows the portal's two tabs ("Cases Currently Under Investigation" and "Archive") as of 28 August 2026; a filing moves to the archive when OCR closes the case. Modelled costs on this site are a method applied to the reported count, using IBM Cost of a Data Breach per-record figures, and are never a cost disclosed by the entity. This row: hhs-breach-archive__2026-08-28.csv, export row 1820.
Corrections: if you represent a listed entity and the portal row has been amended, email [email protected] with the portal entry and we will re-pull the export.