Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing CA-20160902-santa-cruz-county-health-services-agencyHHS OCR Breach Register, California

Breach filing

Archived

Santa Cruz County Health Services Agency: 25,000 individuals, Sep 2016.

Santa Cruz County Health Services Agency reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 2 September 2016. The filing records the organisation as a healthcare provider in California and lists 25,000 individuals affected, which makes it the 165th largest of the 776 California filings on the register and the 42nd largest of the 328 filings submitted nationally in 2016. Among the 41 California filings made in 2016 it ranks 5th.

Individuals affected

25,000

As reported to HHS

Modelled cost (IBM 2025)

$4.00M

Method shown, not disclosed

Rank in CA

165th

of 776 California filings

Rank in 2016

42nd

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
Healthcare Provider
Individuals affected
25,000
Breach submission date
2 September 2016
Submission year
2016
Type of breach
Unauthorized Access/Disclosure
Location of breached information
Paper/Films
Business associate present
No
Portal status
listed in the HHS OCR breach portal archive
Rank in California by size
165th of 776
Rank in 2016 nationally
42nd of 328
California median filing
3,553 individuals
Register id (derived)
CA-20160902-santa-cruz-county-health-services-agency

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 paper records or films. Unauthorized Access/Disclosure is the type recorded on 174 of the 776 California filings (22%) and on 40% of all filings submitted in 2016. Paper/Films appears on 15% of California filings.

No business associate is recorded on the filing; 33% of California filings do involve one. At 25,000 individuals the breach is 7.0 times the California median filing of 3,553 and 6.3 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 25,000 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 $4.00M; the 2026 edition's $192 gives $4.80M. Both are modelled estimates with the method shown, not costs disclosed by Santa Cruz County Health Services Agency. 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), Santa Cruz County Health Services Agency, reported a breach of unsecured PHI when a break-in occurred at the CE's storage area. The CE initially reported that the breach affected approximately 25,000 individuals. However, an internal investigation, conducted with law enforcement assistance, revealed later that no breach had occurred because the break-in did not affect the paper records. OCR provided technical assistance to the CE. The CE implemented additional physical safeguards, updated its HIPAA policies and procedures and trained its staff on privacy and security awareness.

Section F.5 / Modelled cost

25,000 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$4.00M

25,000 x $160

IBM 2026 customer PII, $192 per record

$4.80M

25,000 x $192

Method: individuals affected, as reported by Santa Cruz County Health Services Agency 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 entityTypeIndividualsSubmitted
SCAN Health PlanHealth Plan87,06922 Aug 2016
East Valley Community Health Center, Inc.Healthcare Provider65,00015 Dec 2016
Blue Shield of CaliforniaHealth Plan20,76414 Jan 2016
USC Keck and Norris HospitalsHealthcare Provider16,00021 Sep 2016

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 5481.

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.