Breach filing
ArchivedThe Guidance Center, Inc.: 23,104 individuals, Apr 2022.
The Guidance Center, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 5 April 2022. The filing records the organisation as a healthcare provider in Arizona and lists 23,104 individuals affected, which makes it the 38th largest of the 164 Arizona filings on the register and the 227th largest of the 718 filings submitted nationally in 2022. Among the 16 Arizona filings made in 2022 it ranks 6th.
Individuals affected
23,104
As reported to HHS
Modelled cost (IBM 2025)
$3.70M
Method shown, not disclosed
Rank in AZ
38th
of 164 Arizona filings
Rank in 2022
227th
of 718 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
- 23,104
- Breach submission date
- 5 April 2022
- Submission year
- 2022
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Arizona (AZ)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Arizona by size
- 38th of 164
- Rank in 2022 nationally
- 227th of 718
- Arizona median filing
- 3,146 individuals
- Register id (derived)
- AZ-20220405-guidance-center
Section F.2 / In context
Where this filing sits in Arizona and in 2022
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 94 of the 164 Arizona filings (57%) and on 79% of all filings submitted in 2022. Email appears on 26% of Arizona filings.
No business associate is recorded on the filing; 21% of Arizona filings do involve one. At 23,104 individuals the breach is 7.3 times the Arizona median filing of 3,146 and 5.8 times the national median of 4,000 across all 7,884 filings. It sits in the 10,000 to 99,999 band, which holds 1,938 filings.
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.
Arizona's breach notification statute (A.R.S. 18-551, 18-552) requires notice to affected residents within 45 days after determining a breach occurred. Its attorney general threshold: more than 1,000 Arizona residents (AG and Dept. of Homeland Security). 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 23,104 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 $3.70M; the 2026 edition's $192 gives $4.44M. Both are modelled estimates with the method shown, not costs disclosed by The Guidance Center, Inc.. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.7 times the sector average.
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), The Guidance Center, reported that several employees were victims of an email phishing attack that compromised the protected health information (PHI) of 23,104 individuals. The PHI involved included names, addresses, dates of birth, drivers' license and Social Security numbers, financial information, diagnoses/conditions, lab results, and medication information. The CE notified HHS, affected individuals, the media, and provided substitute notice. In its mitigation efforts, the CE provided complimentary credit monitoring and identity theft services to those affected and implemented additional administrative and technical safeguards to better protect its sensitive data. Staff were retrained on email security. OCR provided technical assistance to the CE.
Section F.5 / Modelled cost
23,104 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.70M
23,104 x $160
IBM 2026 customer PII, $192 per record
$4.44M
23,104 x $192
Method: individuals affected, as reported by The Guidance Center, Inc. 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
Arizona statute and the HIPAA rule
State notification statute
Arizona: A.R.S. 18-551, 18-552
- Notice to individuals
- Within 45 days after determining a breach occurred
- Attorney general threshold
- More than 1,000 Arizona residents (AG and Dept. of Homeland Security) (Within the same 45-day window)
- Private right of action
- No: Only the Arizona Attorney General may enforce
- Penalty
- Up to $10,000 per affected individual, capped at $500,000 per breach, under the Consumer Fraud Act
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
Arizona filings closest in size
Neighbours by size rank among Arizona filings in 2022, topped up from other years where 2022 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Valle del Sol, Inc. | Healthcare Provider | 70,268 | 5 Oct 2022 | |||
| FPS Medical Center | Healthcare Provider | 28,024 | 2 May 2022 | |||
| East Valley Ophthalmology | Healthcare Provider | 20,734 | 15 Jul 2022 | |||
| Orthopedic Specialists of North America, PLLC dba OrthoArizona | Healthcare Provider | 2,748 | 15 Jul 2022 |
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 2591.
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.