Breach filing
ArchivedNorth Memorial Health: 21,236 individuals, Sep 2020.
North Memorial Health reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 30 September 2020. The filing records the organisation as a healthcare provider in Minnesota and lists 21,236 individuals affected, which makes it the 42nd largest of the 189 Minnesota filings on the register and the 191st largest of the 663 filings submitted nationally in 2020. Among the 21 Minnesota filings made in 2020 it ranks 8th.
Individuals affected
21,236
As reported to HHS
Modelled cost (IBM 2025)
$3.40M
Method shown, not disclosed
Rank in MN
42nd
of 189 Minnesota filings
Rank in 2020
191st
of 663 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
- 21,236
- Breach submission date
- 30 September 2020
- Submission year
- 2020
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Minnesota (MN)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Minnesota by size
- 42nd of 189
- Rank in 2020 nationally
- 191st of 663
- Minnesota median filing
- 3,159 individuals
- Register id (derived)
- MN-20200930-north-memorial-health
Section F.2 / In context
Where this filing sits in Minnesota and in 2020
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 114 of the 189 Minnesota filings (60%) and on 69% of all filings submitted in 2020. Network Server appears on 43% of Minnesota filings.
A business associate is recorded as present on the filing, as it is on 35% of Minnesota filings. At 21,236 individuals the breach is 6.7 times the Minnesota median filing of 3,159 and 5.3 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.
Minnesota's breach notification statute (Minn. Stat. 325E.61) 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 500+ residents within 48 hours). 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 21,236 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 $3.40M; the 2026 edition's $192 gives $4.08M. Both are modelled estimates with the method shown, not costs disclosed by North Memorial Health. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.6 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), North Memorial Health, reported that its business associate (BA) experienced a ransomware attack affecting the electronic protected health information (ePHI) of approximately 21,236 individuals. The ePHI involved included names, addresses, dates of birth, and treatment information. The CE notified HHS, affected individuals, the media, and provided substitute notice.
Section F.5 / Modelled cost
21,236 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.40M
21,236 x $160
IBM 2026 customer PII, $192 per record
$4.08M
21,236 x $192
Method: individuals affected, as reported by North Memorial Health 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
Minnesota statute and the HIPAA rule
State notification statute
Minnesota: Minn. Stat. 325E.61
- Notice to individuals
- In the most expedient time possible and without unreasonable delay
- Attorney general threshold
- No general AG requirement (reporting agencies at 500+ residents within 48 hours)
- Private right of action
- No: Only the Minnesota Attorney General may enforce
- Penalty
- Up to $25,000 per violation; contractual waivers of notification are void
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
Minnesota filings closest in size
Neighbours by size rank among Minnesota filings in 2020, topped up from other years where 2020 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Douglas County Hospital dba Alomere Health | Healthcare Provider | 49,859 | 3 Jan 2020 | |||
| People Incorporated | Healthcare Provider | 27,500 | 6 Nov 2020 | |||
| Mille Lacs Health System | Healthcare Provider | 10,630 | 11 May 2020 | |||
| Lifesprk | Healthcare Provider | 9,000 | 17 Mar 2020 |
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 3660.
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.