Form: Cost-of-Breach DisclosureSource: IBM Cost of a Data BreachFiled: 28 Apr 2026
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Filing IL-20141212-clay-county-hospitalHHS OCR Breach Register, Illinois

Breach filing

Archived

Clay County Hospital: 12,621 individuals, Dec 2014.

Clay County Hospital reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 12 December 2014. The filing records the organisation as a healthcare provider in Illinois and lists 12,621 individuals affected, which makes it the 107th largest of the 358 Illinois filings on the register and the 62nd largest of the 314 filings submitted nationally in 2014. Among the 17 Illinois filings made in 2014 it ranks 5th.

Individuals affected

12,621

As reported to HHS

Modelled cost (IBM 2025)

$2.02M

Method shown, not disclosed

Rank in IL

107th

of 358 Illinois filings

Rank in 2014

62nd

of 314 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
12,621
Breach submission date
12 December 2014
Submission year
2014
Type of breach
Unauthorized Access/Disclosure
Location of breached information
Other
Business associate present
No
Portal status
listed in the HHS OCR breach portal archive
Rank in Illinois by size
107th of 358
Rank in 2014 nationally
62nd of 314
Illinois median filing
3,403 individuals
Register id (derived)
IL-20141212-clay-county-hospital

Section F.2 / In context

Where this filing sits in Illinois and in 2014

OCR classifies the incident as unauthorized access or disclosure, with the breached information held in another location. Unauthorized Access/Disclosure is the type recorded on 86 of the 358 Illinois filings (24%) and on 34% of all filings submitted in 2014. Other appears on 7% of Illinois filings.

No business associate is recorded on the filing; 34% of Illinois filings do involve one. At 12,621 individuals the breach is 3.7 times the Illinois median filing of 3,403 and 3.2 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.

Illinois's breach notification statute (815 ILCS 530) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: more than 500 Illinois residents (private collectors); 250 for state agencies. 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 12,621 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 $2.02M; the 2026 edition's $192 gives $2.42M. Both are modelled estimates with the method shown, not costs disclosed by Clay County Hospital. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.4 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 November 2, 2014, the covered entity's (CE) president received an anonymous email threatening to release the protected health information (PHI) of hospital clinic patients to the public unless he or she received a substantial payment from the CE. This threat could have affected patients who visited the hospital on or before February 2012, approximately 12,621 individuals. The CE determined that the CE's servers were not hacked nor were its information systems compromised. OCR determined that the voluntary corrective actions of the CE resolved this matter. Nonetheless, the CE provided breach notification to HHS, potentially affected individuals, and the media, and offered identity theft protection to the notified individuals. Additionally, the CE developed an encryption program and network auditing program. It re-trained staff on its newly implemented programs and its privacy and security policies. OCR obtained documented assurances that the CE implemented corrective action steps noted above..

Section F.5 / Modelled cost

12,621 individuals through IBM's per-record figures

Modelled cost / method shown, not a disclosed cost

Modelled

IBM 2025 customer PII, $160 per record

$2.02M

12,621 x $160

IBM 2026 customer PII, $192 per record

$2.42M

12,621 x $192

Method: individuals affected, as reported by Clay County Hospital 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

Illinois statute and the HIPAA rule

State notification statute

Illinois: 815 ILCS 530

Personal Information Protection Act (PIPA)

Notice to individuals
In the most expedient time possible and without unreasonable delay
Attorney general threshold
More than 500 Illinois residents (private collectors); 250 for state agencies (Within 45 days of discovery or at the time of consumer notice, whichever is sooner)
Private right of action
No: No direct PROA under PIPA; claims may run through the Consumer Fraud Act, and BIPA covers biometric data separately
Penalty
Up to $50,000 per violation under the Consumer Fraud Act; restitution prioritized over penalties

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

Illinois filings closest in size

Neighbours by size rank among Illinois filings in 2014, topped up from other years where 2014 has too few. Filings of 10,000 or more link to their own page.

Covered entityTypeIndividualsSubmitted
Kmart CorporationHealthcare Provider16,44610 Feb 2014
Dennis Flynn MDHealthcare Provider13,64619 Aug 2014
OptumRxBusiness Associate5,69630 Apr 2014
Northwestern Memorial HealthCareHealthcare Provider2,81323 Dec 2014

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 5960.

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.