Breach filing
ArchivedState of North Dakota: 35,416 individuals, Oct 2020.
State of North Dakota reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 27 October 2020. The filing records the organisation as a healthcare provider in North Dakota and lists 35,416 individuals affected, which makes it the 4th largest of the 19 North Dakota filings on the register and the 161st largest of the 663 filings submitted nationally in 2020. It was the only North Dakota filing in 2020.
Individuals affected
35,416
As reported to HHS
Modelled cost (IBM 2025)
$5.67M
Method shown, not disclosed
Rank in ND
4th
of 19 North Dakota filings
Rank in 2020
161st
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
- 35,416
- Breach submission date
- 27 October 2020
- Submission year
- 2020
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- North Dakota (ND)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in North Dakota by size
- 4th of 19
- Rank in 2020 nationally
- 161st of 663
- North Dakota median filing
- 6,457 individuals
- Register id (derived)
- ND-20201027-state-of-north-dakota
Section F.2 / In context
Where this filing sits in North Dakota and in 2020
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 13 of the 19 North Dakota filings (68%) and on 69% of all filings submitted in 2020. Email appears on 32% of North Dakota filings.
No business associate is recorded on the filing; 21% of North Dakota filings do involve one. At 35,416 individuals the breach is 5.5 times the North Dakota median filing of 6,457 and 8.9 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.
North Dakota's breach notification statute (N.D. Cent. Code Ch. 51-30) requires notice to affected residents in the most expedient time possible and without unreasonable delay. Its attorney general threshold: 250 or more North Dakota residents. 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 35,416 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 $5.67M; the 2026 edition's $192 gives $6.80M. Both are modelled estimates with the method shown, not costs disclosed by State of North Dakota. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.0 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 State of North Dakota, reported that several employees were the victims of an email phishing scheme that affected the protected health information (PHI) of 35,416 individuals. The PHI involved included names, dates of birth, Social Security numbers, drivers' license numbers, financial information, diagnoses, and other treatment information. The CE notified HHS, affected individuals, the media, and provided substitute notice. In response to the breach, the CE implemented additional technical and administrative safeguards to better protect its PHI.
Section F.5 / Modelled cost
35,416 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$5.67M
35,416 x $160
IBM 2026 customer PII, $192 per record
$6.80M
35,416 x $192
Method: individuals affected, as reported by State of North Dakota 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
North Dakota statute and the HIPAA rule
State notification statute
North Dakota: N.D. Cent. Code Ch. 51-30
- Notice to individuals
- In the most expedient time possible and without unreasonable delay
- Attorney general threshold
- 250 or more North Dakota residents (Same timeline as individual notification)
- Private right of action
- No: Only the North Dakota Attorney General may enforce
- Penalty
- Up to $5,000 per violation under the consumer fraud statute, plus fees and costs
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
North Dakota filings closest in size
Neighbours by size rank among North Dakota 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 |
|---|---|---|---|---|---|---|
| Adaptive Health Integrations | Healthcare Provider | 510,574 | 11 Apr 2022 | |||
| Dakota Eye Institute | Healthcare Provider | 107,143 | 23 Oct 2023 | |||
| DMS Health Technologies, Inc. | Healthcare Provider | 48,336 | 21 Jun 2023 | |||
| Pembina County Memorial Hospital | Healthcare Provider | 23,811 | 25 Mar 2024 | |||
| Southwest Healthcare Services | Healthcare Provider | 15,996 | 1 Apr 2023 |
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 3603.
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.