Breach filing
ArchivedLegacy Health: 38,000 individuals, Aug 2018.
Legacy Health reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 20 August 2018. The filing records the organisation as a healthcare provider in Oregon and lists 38,000 individuals affected, which makes it the 17th largest of the 120 Oregon filings on the register and the 45th largest of the 369 filings submitted nationally in 2018. Among the 9 Oregon filings made in 2018 it ranks 2nd.
Individuals affected
38,000
As reported to HHS
Modelled cost (IBM 2025)
$6.08M
Method shown, not disclosed
Rank in OR
17th
of 120 Oregon filings
Rank in 2018
45th
of 369 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
- 38,000
- Breach submission date
- 20 August 2018
- Submission year
- 2018
- Type of breach
- Hacking/IT Incident
- Location of breached information
- Business associate present
- No
- State
- Oregon (OR)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Oregon by size
- 17th of 120
- Rank in 2018 nationally
- 45th of 369
- Oregon median filing
- 2,400 individuals
- Register id (derived)
- OR-20180820-legacy-health
Section F.2 / In context
Where this filing sits in Oregon and in 2018
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 63 of the 120 Oregon filings (53%) and on 45% of all filings submitted in 2018. Email appears on 27% of Oregon filings.
No business associate is recorded on the filing; 23% of Oregon filings do involve one. At 38,000 individuals the breach is 16 times the Oregon median filing of 2,400 and 9.5 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.
Oregon's breach notification statute (ORS 646A.600 et seq.) requires notice to affected residents as soon as practicable but no later than 45 days after discovery. Its attorney general threshold: 250 or more Oregon 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 38,000 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 $6.08M; the 2026 edition's $192 gives $7.30M. Both are modelled estimates with the method shown, not costs disclosed by Legacy Health. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 1.1 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.
On June 21, 2018, the covered entity (CE), Legacy Health, learned that an unauthorized third party may have gained access to some employees' email accounts in May 2018, affecting approximately 38,000 individuals. The types of protected health information (PHI) involved in the breach included patients' names, dates of birth, insurance information, billing information, driver's license numbers, Social Security numbers and medical information. The CE provided breach notification to HHS, affected individuals, and the media. Following the breach, the CE began an investigation and engaged a law firm and other companies to assist. As a result of OCR's investigation, the CE implemented enhanced email security protections, implemented multi-factor authentication for all users on all of its systems, and enhanced malware defenses on its firewall.
Section F.5 / Modelled cost
38,000 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$6.08M
38,000 x $160
IBM 2026 customer PII, $192 per record
$7.30M
38,000 x $192
Method: individuals affected, as reported by Legacy 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
Oregon statute and the HIPAA rule
State notification statute
Oregon: ORS 646A.600 et seq.
Oregon Consumer Information Protection Act
- Notice to individuals
- As soon as practicable but no later than 45 days after discovery
- Attorney general threshold
- 250 or more Oregon residents (Within the 45-day notification window)
- Private right of action
- No: No express PROA; remedies may run through the Unlawful Trade Practices Act
- Penalty
- Up to $1,000 per violation; continuing violations up to $500,000
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
Oregon filings closest in size
Neighbours by size rank among Oregon filings in 2018, topped up from other years where 2018 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| The Oregon Clinic, P.C. ("The Oregon Clinic") | Healthcare Provider | 64,487 | 8 May 2018 | |||
| Tillamook Chiropractic, PC | Healthcare Provider | 4,058 | 3 Oct 2018 | |||
| Don White, RN, DC, PC dba Canyon Rd Chiropractic and Massage | Healthcare Provider | 2,900 | 3 Aug 2018 |
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 4759.
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.