Breach filing
ArchivedThe Union Labor Life Insurance Company: 87,400 individuals, May 2019.
The Union Labor Life Insurance Company reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 31 May 2019. The filing records the organisation as a health plan in Maryland and lists 87,400 individuals affected, which makes it the 25th largest of the 170 Maryland filings on the register and the 47th largest of the 511 filings submitted nationally in 2019. Among the 15 Maryland filings made in 2019 it ranks 1st.
Individuals affected
87,400
As reported to HHS
Modelled cost (IBM 2025)
$14.0M
Method shown, not disclosed
Rank in MD
25th
of 170 Maryland filings
Rank in 2019
47th
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
- 87,400
- Breach submission date
- 31 May 2019
- Submission year
- 2019
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Maryland (MD)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Maryland by size
- 25th of 170
- Rank in 2019 nationally
- 47th of 511
- Maryland median filing
- 4,792 individuals
- Register id (derived)
- MD-20190531-union-labor-life-insurance
Section F.2 / In context
Where this filing sits in Maryland 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 117 of the 170 Maryland filings (69%) and on 61% of all filings submitted in 2019. Email appears on 30% of Maryland filings.
No business associate is recorded on the filing; 38% of Maryland filings do involve one. At 87,400 individuals the breach is 18 times the Maryland median filing of 4,792 and 22 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.
Maryland's breach notification statute (Md. Code, Com. Law 14-3504) requires notice to affected residents within 45 days after discovery or notification of the breach. Its attorney general threshold: all breaches (AG notified before individual notices are sent). 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 87,400 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 $14.0M; the 2026 edition's $192 gives $16.8M. Both are modelled estimates with the method shown, not costs disclosed by The Union Labor Life Insurance Company. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 2.5 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 covered entity (CE), The Union Labor Life Insurance Company, reported that an employee was the victim of an email phishing attack that affected the electronic protected health information (ePHI) of 186,900 individuals. The ePHI involved included names, dates of birth, addresses, Social Security numbers, diagnoses, lab results, and treatment information. The CE notified HHS, affected individuals, and the media. In response to the breach, the CE implemented additional technical safeguards and retrained its staff on recognizing and responding to fraudulent email communications. OCR obtained assurances that the CE implemented the corrective actions noted.
Section F.5 / Modelled cost
87,400 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$14.0M
87,400 x $160
IBM 2026 customer PII, $192 per record
$16.8M
87,400 x $192
Method: individuals affected, as reported by The Union Labor Life Insurance Company 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
Maryland statute and the HIPAA rule
State notification statute
Maryland: Md. Code, Com. Law 14-3504
- Notice to individuals
- Within 45 days after discovery or notification of the breach
- Attorney general threshold
- All breaches (AG notified before individual notices are sent) (Before individual notifications are sent)
- Private right of action
- No: No PROA under the breach statute; AG enforcement only
- Penalty
- Unfair or deceptive trade practice; up to $10,000 per violation, $25,000 per repeat violation
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
Maryland filings closest in size
Neighbours by size rank among Maryland 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 |
|---|---|---|---|---|---|---|
| Onyx Technology LLC | Business Associate | 96,814 | 12 Aug 2022 | |||
| Columbia Medical PracticeOpen | Healthcare Provider | 94,131 | 5 Dec 2025 | |||
| LifeBridge Community Gastroenterology, LLC dba Woodholme Gastroenterology | Healthcare Provider | 66,342 | 30 Apr 2021 | |||
| Magellan Healthcare | Business Associate | 55,637 | 17 Sep 2019 | |||
| Takai, Hoover, and Hsu, P.A. | Healthcare Provider | 16,542 | 29 May 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 4427.
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.