Breach filing
ArchivedAon Consulting: 22,642 individuals, Sep 2010.
Aon Consulting reported a breach of unsecured protected health information to the HHS Office for Civil Rights on 7 September 2010. The filing records the organisation as a business associate in Pennsylvania and lists 22,642 individuals affected, which makes it the 76th largest of the 339 Pennsylvania filings on the register and the 23rd largest of the 199 filings submitted nationally in 2010. Among the 11 Pennsylvania filings made in 2010 it ranks 3rd.
Individuals affected
22,642
As reported to HHS
Modelled cost (IBM 2025)
$3.62M
Method shown, not disclosed
Rank in PA
76th
of 339 Pennsylvania filings
Rank in 2010
23rd
of 199 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
- 22,642
- Breach submission date
- 7 September 2010
- Submission year
- 2010
- Type of breach
- Other
- Location of breached information
- Network Server
- Business associate present
- Yes
- State
- Pennsylvania (PA)
- Portal status
- listed in the HHS OCR breach portal archive
- Rank in Pennsylvania by size
- 76th of 339
- Rank in 2010 nationally
- 23rd of 199
- Pennsylvania median filing
- 3,905 individuals
- Register id (derived)
- PA-20100907-aon-consulting
Section F.2 / In context
Where this filing sits in Pennsylvania and in 2010
OCR classifies the incident as a breach of another type, with the breached information held in a network server. Other is the type recorded on 5 of the 339 Pennsylvania filings (1%) and on 12% of all filings submitted in 2010. Network Server is the most common location in the state, appearing on 51% of Pennsylvania filings.
A business associate is recorded as present on the filing, as it is on 34% of Pennsylvania filings. At 22,642 individuals the breach is 5.8 times the Pennsylvania median filing of 3,905 and 5.7 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.
Pennsylvania's breach notification statute (73 Pa. Stat. 2301 et seq.) requires notice to affected residents without unreasonable delay. Its attorney general threshold: more than 500 Pennsylvania 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 22,642 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 $3.62M; the 2026 edition's $192 gives $4.35M. Both are modelled estimates with the method shown, not costs disclosed by Aon Consulting. For scale, IBM's 2026 average cost of a healthcare breach is $6.64M, so this filing models at 0.7 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 prepared a document as part of a request for proposal for the covered entity's vision benefit program which mistakenly included protected health information of 22,642 individuals. The document was posted online for five days. The protected health information involved in the breach included social security numbers, dates of birth, gender, zip codes, and vision plan enrollment information. In response to this incident, the covered entity implemented additional safeguards to prevent this type of impermissible disclosure of protected health information. In particular, the covered entity will now require several layers of review before allowing public disclosure of documents prepared by the business associate. The covered entity also took steps to enforce the requirements of its business associate agreement with Aon Consulting. Aon will provide affected individuals with free credit monitoring, fraud resolution resources, and identity theft insurance. Additionally, the business associate has provided assurances to the covered entity that it has taken steps to prevent this type of impermissible disclosure in the future.
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Section F.5 / Modelled cost
22,642 individuals through IBM's per-record figures
Modelled cost / method shown, not a disclosed cost
ModelledIBM 2025 customer PII, $160 per record
$3.62M
22,642 x $160
IBM 2026 customer PII, $192 per record
$4.35M
22,642 x $192
Method: individuals affected, as reported by Aon Consulting 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
Pennsylvania statute and the HIPAA rule
State notification statute
Pennsylvania: 73 Pa. Stat. 2301 et seq.
Breach of Personal Information Notification Act (amended by Act 33 of 2024)
- Notice to individuals
- Without unreasonable delay
- Attorney general threshold
- More than 500 Pennsylvania residents (Without unreasonable delay (online portal))
- Private right of action
- Yes: Treated as an unfair or deceptive practice; consumers may pursue civil suits
- Penalty
- AG enforcement via civil actions, injunctive relief, civil penalties, and restitution
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
Pennsylvania filings closest in size
Neighbours by size rank among Pennsylvania filings in 2010, topped up from other years where 2010 has too few. Filings of 10,000 or more link to their own page.
| Covered entity | Type | Individuals | Submitted | Breach type | Location | BA |
|---|---|---|---|---|---|---|
| Iron Mountain Data Products, Inc. (now known as | Business Associate | 800,000 | 19 Jul 2010 | |||
| Siemens Medical Solutions, USA, Inc | Business Associate | 130,495 | 4 Jun 2010 | |||
| Thomas Jefferson University Hospitals, Inc. | Healthcare Provider | 21,000 | 9 Aug 2010 | |||
| University of Pittsburgh Student Health Center | Healthcare Provider | 8,000 | 2 Apr 2010 |
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 7027.
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.