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California Regulator Settles with Anthem Blue Cross Over SSN Mailing Error, $150K Penalty

Blue Cross of CaliforniaOctober 1, 2012California Attorney General

Penalty Amount

$150,000

Summary

Anthem Blue Cross printed Social Security numbers on mailed letters, exposing the personal information of over 33,000 Medicare subscribers. The settlement requires the company to improve data security measures, provide employee training, and pay $150,000. This action aims to prevent future privacy violations.

Remedy

Anthem must pay $150,000, implement new technical safeguards for data management, restrict employee access to Social Security numbers, and provide enhanced data security training for all associates.

Monetary PenaltyCompliance Program

Contract Impact

In-house legal teams should scrutinize all agreements involving customer communications and data processing, particularly with mailing service providers, third-party logistics vendors, and any entities handling personally identifiable information (PII). Key clauses to review include data security standards (e.g., encryption, redaction, and access controls for physical mail), mandatory employee training on data handling, data retention and disposal policies, and breach notification procedures. Given the exposure of Social Security numbers via mailed letters, contracts must explicitly require encryption or redaction of sensitive PII in physical correspondence, regular security audits, and immediate reporting of data mishandling. Consider adding indemnification provisions for privacy violations and requiring vendors to comply with frameworks like NIST or ISO 27001. Updates may also be needed in customer-facing agreements to clarify data handling practices and in employee contracts to reinforce confidentiality obligations.

Contract Search Terms

data minimizationencryption requirementsaccess controlssecure mailing proceduresPII handling protocolsdata retention schedulebreach notification clauseemployee training requirementsvendor data security standardsaudit rights

Violation Types

Entity Details

Entity

Blue Cross of California

Also known as: Anthem

Industry

Healthcare

Official Sources

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