Penalty Amount
$130,000
Consumers Affected
55,715
Command Marketing Innovations, LLC and Strategic Content Imaging, LLC settled allegations that they violated the New Jersey Consumer Fraud Act and HIPAA by failing to safeguard protected health information, exposing the data of 55,715 New Jersey residents. The companies agreed to pay $130,000 in penalties and implement comprehensive security measures, including appointing security officers and providing employee training.
The companies must pay $130,000 in penalties, with $65,000 suspended upon compliance, implement a comprehensive security information program, appoint Chief Information Security Officers and Chief Privacy Officers, provide security awareness training, and obtain client approval for material changes to printing processes.
In-house legal teams should review all vendor agreements with healthcare entities or business associates, particularly those involving mailing, printing, or data processing services. Key clauses to examine include data security obligations, HIPAA compliance requirements, breach notification procedures, protected health information (PHI) handling protocols, employee training mandates, and provisions requiring the appointment of security officers. Given the allegations of inadequate safeguards, contracts may need amendments to strengthen security measures (e.g., encryption, access controls), mandate regular risk assessments and audits, specify detailed breach response timelines, require documented employee training, and ensure alignment with HIPAA and state consumer protection standards.
Entity
Command Marketing Innovations, LLC and Strategic Content Imaging, LLC
Also known as: Command Marketing Innovations and Strategic Content Imaging
Industry
OtherOfficial Press Release
https://www.njoag.gov/acting-ag-bruck-reaches-settlement-with-two-printing-companies-over-improper-disclosures-of-protected-health-information/
Command Marketing Innovations LLC and Strategic Content Imag
https://www.nj.gov/oag/newsreleases21/Command-Marketing-Innovations-LLC-and-Strategic-Content-Imaging-LLC.pdf
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"Command Marketing Innovations, LLC (“CMI”), and Strategic Content Imaging, LLC (“SCI”)"
"pay $130,000 in penalties"
"New Jersey Consumer Fraud Act (CFA)"
"Health Insurance Portability and Accountability Act (“HIPAA”)"
"Security Breach Exposed Personal and Protected Healthcare Information"
"caused improper disclosure of protected health information (PHI)"
$650K
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$400.0M
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