Breach filing
ArchivedDelta Dental of Illinois: 15,466 individuals, Oct 2019.
Delta Dental of Illinois reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 25 October 2019. The filing records the organisation as a health plan in Illinois and lists 15,466 individuals affected, which makes it the 100th largest of the 358 Illinois filings on the register and the 124th largest of the 511 filings submitted nationally in 2019. Among the 21 Illinois filings made in 2019 it ranks 2nd.
Individuals affected
15,466
As reported to HHS
Modelled cost (IBM 2025)
$2.47M
Method shown, not disclosed
Rank in IL
100th
of 358 Illinois filings
Rank in 2019
124th
of 511 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
- Health Plan
- Individuals affected
- 15,466
- Breach submission date
- 25 October 2019
- Submission year
- 2019
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Illinois (IL)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Illinois by size
- 100th of 358
- Rank in 2019 nationally
- 124th of 511
- Illinois median filing
- 3,403 individuals
- Register id (derived)
- IL-20191025-delta-dental-of-illinois
Section F.2 / In context
Where this filing sits in Illinois and in 2019
OCR classifies the incident as a hacking or IT incident, with the breached information held in email. Hacking/IT Incident is the type recorded on 201 of the 358 Illinois filings (56%) and on 61% of all filings submitted in 2019. Email appears on 23% of Illinois filings.
No business associate is recorded on the filing; 34% of Illinois filings do involve one. At 15,466 individuals the breach is 4.5 times the Illinois median filing of 3,403 and 3.9 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 15,466 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 $2.47M; the 2026 edition's $192 gives $2.97M. Both are modelled estimates with the method shown, not costs disclosed by Delta Dental of Illinois. 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.
This case has been consolidated into an existing compliance review involving the same breach incident.
Section F.5 / Modelled cost
15,466 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$2.47M
15,466 x $160
IBM 2026 customer PII, $192 per record
$2.97M
15,466 x $192
Method: individuals affected, as reported by Delta Dental of Illinois 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 2019, topped up from other years where 2019 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Rush University Medical Center | Healthcare Provider | 44,924 | 28 Feb 2019 | |||
| Sinai Health System | Healthcare Provider | 12,578 | 13 Dec 2019 | |||
| Beer Industry - Local Union No. 703 Health and Welfare Fund | Health Plan | 9,279 | 28 Nov 2019 |
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 4196.
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.