Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing CA-20230407-brightlineHHS OCR Breach Register, California

Breach filing

Archived

Brightline, Inc.: 473,467 individuals, Apr 2023.

Brightline, Inc. reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 7 April 2023. The filing records the organisation as a business associate in California and lists 473,467 individuals affected, which makes it the 29th largest of the 776 California filings on the register and the 65th largest of the 746 filings submitted nationally in 2023. Among the 82 California filings made in 2023 it ranks 9th. Brightline, Inc. submitted 6 further reports on the same day (199,753, 31,440, 21,830, 7,672, 7,411 and 4,044 individuals); this page covers the largest and lists the others below.

Individuals affected

473,467

As reported to HHS

Modelled cost (IBM 2025)

$75.8M

Upper bound, method shown

Rank in CA

29th

of 776 California filings

Rank in 2023

65th

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
Business Associate
Individuals affected
473,467
Breach submission date
7 April 2023
Submission year
2023
Type of breach
Hacking/IT Incident
Location of breached information
Network Server
Business associate present
Yes
Portal status
listed in the HHS OCR breach portal archive
Rank in California by size
29th of 776
Rank in 2023 nationally
65th of 746
California median filing
3,553 individuals
Register id (derived)
CA-20230407-brightline

Section F.2 / In context

Where this filing sits in California and in 2023

OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server. Hacking/IT Incident is the type recorded on 398 of the 776 California filings (51%) and on 82% of all filings submitted in 2023. Network Server appears on 43% of California filings.

A business associate is recorded as present on the filing, as it is on 33% of California filings. At 473,467 individuals the breach is 133 times the California median filing of 3,553 and 118 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.

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 473,467 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 $75.8M; the 2026 edition's $192 gives $90.9M. Both are modelled estimates with the method shown, not costs disclosed by Brightline, Inc.. 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 business associate (BA), Brightline, reported that its third-party provider was the victim of a cyber-attack affecting the protected health information (PHI) of 473,467 individuals. The PHI involved included names, dates of birth, addresses, member and group identification numbers, and gender identification. The BA notified HHS, affected individuals, the media, and provided substitute notice. In response to the breach, the BA provided complimentary credit monitoring services and implemented additional security and technical safeguards. OCR provided the BA with technical assistance regarding the HIPAA Privacy, Security, and Breach Notification Rules.

Section F.4 / Same-day filings

6 further reports by Brightline, Inc. on 7 April 2023

Separate rows on the HHS portal with their own counts; this page covers the largest and lists the rest here rather than giving each its own page.

Covered entityTypeIndividualsSubmitted
Brightline, Inc.Business Associate199,7537 Apr 2023
Brightline, Inc.Business Associate31,4407 Apr 2023
Brightline, Inc.Business Associate21,8307 Apr 2023
Brightline, Inc.Business Associate7,6727 Apr 2023
Brightline, Inc.Business Associate7,4117 Apr 2023
Brightline, Inc.Business Associate4,0447 Apr 2023

Section F.5 / Modelled cost

473,467 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$75.8M

473,467 x $160

IBM 2026 customer PII, $192 per record

$90.9M

473,467 x $192

Method: individuals affected, as reported by Brightline, 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

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 2023, topped up from other years where 2023 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Sutter HealthHealthcare Provider845,4413 Nov 2023
California Physicians' Service d/b/a Blue Shield of CaliforniaHealth Plan636,84917 Nov 2023
Orrick, Herrington & Sutcliffe LLPBusiness Associate342,17630 Jun 2023
Oak Valley Hospital DistrictHealthcare Provider284,62915 Sep 2023

Index / Companion schedules

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 1852.

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.