Breach filing
ArchivedBlue Shield of California: 20,764 individuals, Jan 2016.
Blue Shield of California reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 14 January 2016. The filing records the organisation as a health plan in California and lists 20,764 individuals affected, which makes it the 175th largest of the 776 California filings on the register and the 50th largest of the 328 filings submitted nationally in 2016. Among the 41 California filings made in 2016 it ranks 6th.
Individuals affected
20,764
As reported to HHS
Modelled cost (IBM 2025)
$3.32M
Method shown, not disclosed
Rank in CA
175th
of 776 California filings
Rank in 2016
50th
of 328 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
- Health Plan
- Individuals affected
- 20,764
- Breach submission date
- 14 January 2016
- Submission year
- 2016
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Network Server
- Business associate present
- No
- State
- California (CA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in California by size
- 175th of 776
- Rank in 2016 nationally
- 50th of 328
- California median filing
- 3,553 individuals
- Register id (derived)
- CA-20160114-blue-shield-of-california
Section F.2 / In context
Where this filing sits in California and in 2016
OCR classifies the incident as unauthorized access or disclosure, with the breached information held in a network server. Unauthorized Access/Disclosure is the type recorded on 174 of the 776 California filings (22%) and on 40% of all filings submitted in 2016. Network Server appears on 43% of California filings.
No business associate is recorded on the filing; 33% of California filings do involve one. At 20,764 individuals the breach is 5.8 times the California median filing of 3,553 and 5.2 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.
California's breach notification statute (Cal. Civ. Code 1798.82) requires notice to affected residents within 30 calendar days of discovery (effective 1 January 2026, SB 446). Its attorney general threshold: more than 500 California 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 20,764 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 $3.32M; the 2026 edition's $192 gives $3.99M. Both are modelled estimates with the method shown, not costs disclosed by Blue Shield of California. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.6 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.
On December 7, 2015, Blue Shield of California, the covered entity (CE), discovered that its servers were breached via social engineering at its call centers in Costa Rica. The breach affected 20,764 patients' protected health information (PHI). The types of PHI involved included patients' names, addresses, dates of births, and social security numbers. The CE provided breach notification to HHS, affected individuals, the media. In response to the breach, the CE disabled all existing login credentials and manually distributed new passwords. It trained all call center workforce members about the risks of social engineering and implemented two-factor authentication for external access to its network via its virtual private network (VPN). The CE also provided OCR with additional documentation as relevant to the breach investigation, including its HIPAA Notice of Privacy Practices Policy. OCR obtained assurances that the CE implemented the corrective actions listed above.
Section F.5 / Modelled cost
20,764 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.32M
20,764 x $160
IBM 2026 customer PII, $192 per record
$3.99M
20,764 x $192
Method: individuals affected, as reported by Blue Shield of California 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
California statute and the HIPAA rule
State notification statute
California: Cal. Civ. Code 1798.82
- Notice to individuals
- Within 30 calendar days of discovery (effective 1 January 2026, SB 446)
- Attorney general threshold
- More than 500 California residents (Within 15 calendar days after notifying affected consumers)
- Private right of action
- Yes: Under CCPA Civ. Code 1798.150 for breaches from failure to maintain reasonable security; $107-$799 per consumer per incident (CPI-adjusted from $100-$750, effective Jan 2025)
- Penalty
- CCPA civil penalties of $2,663 per violation, $7,988 per intentional violation (CPI-adjusted, effective Jan 2025); CCPA private right of action for security-failure breaches
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
California filings closest in size
Neighbours by size rank among California filings in 2016, topped up from other years where 2016 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| East Valley Community Health Center, Inc. | Healthcare Provider | 65,000 | 15 Dec 2016 | |||
| Santa Cruz County Health Services Agency | Healthcare Provider | 25,000 | 2 Sep 2016 | |||
| USC Keck and Norris Hospitals | Healthcare Provider | 16,000 | 21 Sep 2016 | |||
| Silver Creek Fitness & Physical Therapy, Silver Creek Physical Therapy Gilroy, Silver Creek Physical Therapy Sunnyvale, Silver Creek Physical Therapy | Healthcare Provider | 8,009 | 24 Oct 2016 |
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 5676.
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.