Penalty Amount
$2,000,000
Cottage Health System experienced two data breaches exposing medical information of over 50,000 patients due to inadequate security measures. The settlement requires a $2 million penalty and upgrades to security practices, including designating a Chief Privacy Officer.
Cottage Health must pay $2 million, implement and maintain reasonable security practices for patient information, designate a Chief Privacy Officer, and conduct periodic risk assessments.
In-house legal teams should review all agreements involving protected health information (PHI), including Business Associate Agreements (BAAs) with vendors, patient consent and service agreements, and employee confidentiality/access agreements. Focus on clauses specifying data security standards (encryption, access controls), breach notification timelines and responsibilities, audit rights, and requirements for risk assessments. Given the settlement's mandate for a Chief Privacy Officer and security upgrades, contracts may need amendments to explicitly require these roles/procedures, mandate regular security audits, enforce specific technical safeguards, and clarify liability for inadequate protection of medical data.
Entity
Cottage Health System
Industry
HealthcareOfficial Press Release
Conformed Stipulation with Exhibit FINAL (1)
https://oag.ca.gov/system/files/attachments/press_releases/Conformed%20Stipulation%20with%20Exhibit%20--%20FINAL%20%281%29.pdf
Conformed Cottage Complaint SIGNED
https://oag.ca.gov/system/files/attachments/press_releases/Conformed%20Cottage%20Complaint%20SIGNED.PDF
California Attorney General Enforcement Page
https://oag.ca.gov/privacy/privacy-enforcement-actions
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The California Privacy Protection Agency (CalPrivacy) joined a coalition of 18 Attorneys General and state agencies in opposing the proposed SECURE Data Act, a federal privacy bill that would preempt stronger state privacy laws like the CCPA. The coalition argues the bill would weaken consumer privacy protections, limit enforcement remedies, and undermine California's Delete Request and Opt-out Platform (DROP).
$12.8M
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The California Privacy Protection Agency Board voted to support two bills (AB 1542 and SB 1106) and took a 'support if amended' position on a third bill (AB 883). These bills aim to strengthen privacy protections by expanding sensitive data protections, improving deletion rights under the Delete Act, and providing expedited deletion for elected officials and judges.
The California Privacy Protection Agency sent a letter to Congress opposing the SECURE Data Act, a federal bill that would preempt state privacy laws like the CCPA and Delete Act. The letter argues the bill would eliminate rights for 40 million Californians, including the DROP platform and opt-out preference signal requirements, and urges Congress to set a floor rather than a ceiling on privacy protections.
California Attorney General Rob Bonta, joined by attorneys general from seven other states, filed a lawsuit to block the $6.2 billion merger between Nexstar Media Group and Tegna Inc. The lawsuit alleges the merger violates Section 7 of the Clayton Act by reducing competition in local TV markets, leading to higher prices, less local news, and job losses.