Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing GA-20120418-emory-healthcareHHS OCR Breach Register, Georgia

Breach filing

Archived

Emory Healthcare: 315,000 individuals, Apr 2012.

Emory Healthcare reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 18 April 2012. The filing records the organisation as a healthcare provider in Georgia and lists 315,000 individuals affected, which makes it the 16th largest of the 226 Georgia filings on the register and the 2nd largest of the 218 filings submitted nationally in 2012. Among the 8 Georgia filings made in 2012 it ranks 1st.

Individuals affected

315,000

As reported to HHS

Modelled cost (IBM 2025)

$50.4M

Upper bound, method shown

Rank in GA

16th

of 226 Georgia filings

Rank in 2012

2nd

of 218 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
315,000
Breach submission date
18 April 2012
Submission year
2012
Type of breach
Other, Unknown
Location of breached information
Other
Business associate present
No
Portal status
listed in the HHS OCR breach portal archive
Rank in Georgia by size
16th of 226
Rank in 2012 nationally
2nd of 218
Georgia median filing
5,232 individuals
Register id (derived)
GA-20120418-emory-healthcare

Section F.2 / In context

Where this filing sits in Georgia and in 2012

OCR classifies the incident as a breach of another type and a breach of unknown type, with the breached information held in another location. Other is the type recorded on 5 of the 226 Georgia filings (2%) and on 9% of all filings submitted in 2012. Other appears on 5% of Georgia filings.

No business associate is recorded on the filing; 34% of Georgia filings do involve one. At 315,000 individuals the breach is 60 times the Georgia median filing of 5,232 and 79 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.

Georgia's breach notification statute (Ga. Code 10-1-912) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: no general AG requirement (reporting agencies at 10,000+ 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 315,000 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 $50.4M; the 2026 edition's $192 gives $60.5M. Both are modelled estimates with the method shown, not costs disclosed by Emory Healthcare. 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.

On February 20, 2012, the covered entity (CE), Emory Healthcare, discovered that ten unencrypted back-up compact disks (CDs) containing electronic protected health information (ePHI) were missing. The types of ePHI involved in the breach included clinical and demographic data for 315,000 surgical patients treated at three locations between September 1990 and April 2007. The information on the CDs could only easily be read using decommissioned software. The CE provided breach notification to HHS, affected individuals, and the media. Following the breach, the CE required every department to inventory and properly store or destroy PHI. It also distributed educational material to all staff. OCR obtained assurances that the CE implemented the corrective actions listed above.

Section F.5 / Modelled cost

315,000 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Upper bound

IBM 2025 customer PII, $160 per record

$50.4M

315,000 x $160

IBM 2026 customer PII, $192 per record

$60.5M

315,000 x $192

Method: individuals affected, as reported by Emory Healthcare 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

Georgia statute and the HIPAA rule

State notification statute

Georgia: Ga. Code 10-1-912

Personal Identity Protection Act

Notice to individuals
In the most expedient time possible and without unreasonable delay
Attorney general threshold
No general AG requirement (reporting agencies at 10,000+ residents)
Private right of action
No: No direct individual lawsuits for notification failures
Penalty
No explicit statutory penalties; possible exposure under the Fair Business Practices 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

Georgia filings closest in size

Neighbours by size rank among Georgia filings in 2012, topped up from other years where 2012 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Navicent Health, Inc.Healthcare Provider404,99322 Mar 2019
Georgia Department of Community HealthHealth Plan355,1272 Mar 2015
Cytometry Specialists, Inc., d/b/a CSI LaboratoriesHealthcare Provider312,00025 Mar 2022
PST Services, IncBusiness Associate13,0748 Oct 2012
Phoebe Putney Memorial Hospital, Inc.Healthcare Provider12,93724 May 2012

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 6693.

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.