Breach filing
ArchivedCerebral, Inc: 3,179,835 individuals, Mar 2023.
Cerebral, Inc reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 1 March 2023. The filing records the organisation as a business associate in Delaware and lists 3,179,835 individuals affected, which makes it the 1st largest of the 31 Delaware filings on the register and the 13th largest of the 746 filings submitted nationally in 2023. Among the 3 Delaware filings made in 2023 it ranks 1st.
Individuals affected
3,179,835
As reported to HHS
Modelled cost (IBM 2025)
$509M
Upper bound, method shown
Rank in DE
1st
of 31 Delaware filings
Rank in 2023
13th
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
- 3,179,835
- Breach submission date
- 1 March 2023
- Submission year
- 2023
- Type of breach
- Unauthorized Access/Disclosure
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Delaware (DE)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Delaware by size
- 1st of 31
- Rank in 2023 nationally
- 13th of 746
- Delaware median filing
- 14,095 individuals
- Register id (derived)
- DE-20230301-cerebral
Section F.2 / In context
Where this filing sits in Delaware and in 2023
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 8 of the 31 Delaware filings (26%) and on 16% of all filings submitted in 2023. Network Server is the most common location in the state, appearing on 61% of Delaware filings.
A business associate is recorded as present on the filing, as it is on 39% of Delaware filings. At 3,179,835 individuals the breach is 226 times the Delaware median filing of 14,095 and 795 times the national median of 4,000 across all 7,884 filings. It is one of 149 filings on the register of one million 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.
Delaware's breach notification statute (Del. Code tit. 6, Ch. 12B) requires notice to affected residents without unreasonable delay, no later than 60 days after determining a breach occurred. Its attorney general threshold: 500 or more Delaware 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 3,179,835 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 $509M; the 2026 edition's $192 gives $611M. Both are modelled estimates with the method shown, not costs disclosed by Cerebral, 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.
Cerebral, the business associate (BA) reported that it may have impermissibly disclosed the protected health information (PHI) of 3,179,835 individuals through the use of Internet tracking technologies. The PHI involved include names, addresses birthdates, diagnoses, and other treatment information. The BA notified HHS, affected individuals, the media, and provided substitute notice on its website. In response to the breach, Cerebral provided complimentary credit monitoring services and revised its policies and procedures, retrained workforce members, and implemented additional administrative and technical safeguards.
Section F.5 / Modelled cost
3,179,835 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
Upper boundIBM 2025 customer PII, $160 per record
$509M
3,179,835 x $160
IBM 2026 customer PII, $192 per record
$611M
3,179,835 x $192
Method: individuals affected, as reported by Cerebral, 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
Delaware statute and the HIPAA rule
State notification statute
Delaware: Del. Code tit. 6, Ch. 12B
- Notice to individuals
- Without unreasonable delay, no later than 60 days after determining a breach occurred
- Attorney general threshold
- 500 or more Delaware residents (No later than when individual notices are sent)
- Private right of action
- No: Statute preserves existing common-law and other statutory rights
- Penalty
- Enforced by the AG Consumer Protection Division; may recover direct economic damages
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
Delaware filings closest in size
Neighbours by size rank among Delaware 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 |
|---|---|---|---|---|---|---|
| ConnectOnCall.com, LLC | Business Associate | 914,138 | 11 Dec 2024 | |||
| Bayhealth Medical Center | Healthcare Provider | 497,047 | 4 Oct 2024 | |||
| Simon Eye Management | Healthcare Provider | 144,780 | 14 Sep 2021 | |||
| La Red Health Center | Healthcare Provider | 39,759 | 20 Oct 2023 | |||
| Henrietta Johnson Medical Center | Healthcare Provider | 4,001 | 27 Jun 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 1927.
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.