Breach filing
ArchivedKirkland & Ellis LLP: 48,802 individuals, Feb 2024.
Kirkland & Ellis LLP reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 29 February 2024. The filing records the organisation as a business associate in Illinois and lists 48,802 individuals affected, which makes it the 61st largest of the 358 Illinois filings on the register and the 182nd largest of the 741 filings submitted nationally in 2024. Among the 44 Illinois filings made in 2024 it ranks 13th.
Individuals affected
48,802
As reported to HHS
Modelled cost (IBM 2025)
$7.81M
Method shown, not disclosed
Rank in IL
61st
of 358 Illinois filings
Rank in 2024
182nd
of 741 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
- 48,802
- Breach submission date
- 29 February 2024
- Submission year
- 2024
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Illinois (IL)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Illinois by size
- 61st of 358
- Rank in 2024 nationally
- 182nd of 741
- Illinois median filing
- 3,403 individuals
- Register id (derived)
- IL-20240229-kirkland-and-ellis
Section F.2 / In context
Where this filing sits in Illinois and in 2024
OCR classifies the incident as a hacking or IT incident, with the breached information held in a network server. Hacking/IT Incident is the type recorded on 201 of the 358 Illinois filings (56%) and on 83% of all filings submitted in 2024. Network Server appears on 43% of Illinois filings.
A business associate is recorded as present on the filing, as it is on 34% of Illinois filings. At 48,802 individuals the breach is 14 times the Illinois median filing of 3,403 and 12 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 48,802 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 $7.81M; the 2026 edition's $192 gives $9.37M. Both are modelled estimates with the method shown, not costs disclosed by Kirkland & Ellis LLP. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.4 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.
The business associate (BA), Kirkland & Ellis, reported that a software application it used exposed the protected health information (PHI) of 48,802 individuals. The PHI involved included names, Social Security and drivers' license numbers, addresses, dates of birth, financial and claims information, diagnoses, lab results, medications, and other treatment information. The BA notified HHS, the affected individuals, the media, and provided substitute notice. In response to the breach, the BA provided complimentary credit monitoring services and implemented additional administrative and technical safeguards to better protect PHI.
Section F.5 / Modelled cost
48,802 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$7.81M
48,802 x $160
IBM 2026 customer PII, $192 per record
$9.37M
48,802 x $192
Method: individuals affected, as reported by Kirkland & Ellis LLP 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 2024, topped up from other years where 2024 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| VisionPoint Eye Center, PLLC | Healthcare Provider | 66,926 | 15 Dec 2024 | |||
| Orsini Pharmaceutical Services, LLC | Healthcare Provider | 56,989 | 8 Mar 2024 | |||
| HAH Group Holding Company, LLC d/b/a "Help At Home" | Healthcare Provider | 26,744 | 18 Aug 2024 | |||
| Fairfield Memorial Hospital Association | Healthcare Provider | 25,093 | 15 Aug 2024 |
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 1144.
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.