Penalty Amount
$450,000
Consumers Affected
250,000
Refuah Health Center, Inc. failed to implement adequate data security measures, leading to a ransomware attack that compromised the personal and health information of approximately 250,000 New Yorkers. The New York Attorney General reached a settlement requiring Refuah to invest $1.2 million in cybersecurity improvements and pay $450,000 in penalties.
Refuah must invest $1.2 million to develop and maintain stronger information security programs, implement policies for data access, use multi-factor authentication, rotate credentials, conduct semi-annual audits, encrypt all consumer information, monitor network activity, and maintain an incident response plan. Additionally, Refuah must pay $450,000 in penalties and costs, with $100,000 suspended upon spending the $1.2 million.
In-house legal teams should review all agreements involving the handling of personal and health information, including vendor contracts with IT/cloud service providers, patient consent and authorization forms, and business associate agreements governed by HIPAA. Key clauses to scrutinize are data security standards (mandating encryption, multi-factor authentication, and access controls), breach notification procedures, audit and monitoring rights, and data retention/destruction terms. Given the settlement's focus on inadequate access controls and encryption, contracts must be updated to require specific technical safeguards such as MFA, regular credential rotation, deactivation of inactive accounts, and encryption of sensitive data at rest and in transit. Additionally, ensure agreements include robust incident response obligations, regular security assessments, and clear liability provisions for data breaches.
Entity
Refuah Health Center, Inc.
Also known as: Refuah Health Center
Industry
HealthcareOfficial Press Release
https://ag.ny.gov/press-release/2024/attorney-general-james-reaches-agreement-hudson-valley-health-care-provider
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New York Attorney General Enforcement Page
https://ag.ny.gov/press-releases
"Refuah Health Center, Inc."
"$450,000"
"failed to maintain appropriate controls to protect and limit access to sensitive data"
"compromised the personal and private health information"
$2.6M
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$1.9M
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