Court Rules
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Consent DecreeMedium Risk

NJ AG Fines Printing Companies $130K for HIPAA Data Breach

Command Marketing Innovations, LLC and Strategic Content Imaging, LLCNovember 10, 2021New Jersey Attorney General

Penalty Amount

$130,000

Consumers Affected

55,715

Summary

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.

Remedy

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.

Monetary PenaltyCompliance Program

Contract Impact

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.

Contract Search Terms

HIPAA Business Associate AgreementData Security AddendumBreach Notification ClauseProtected Health Information (PHI) HandlingEmployee Training on Data PrivacySecurity Officer AppointmentData Encryption StandardsRisk Assessment RequirementsData Retention and DisposalAudit Rights

Laws Cited

New Jersey Consumer Fraud ActHealth Insurance Portability and Accountability Act

Violation Types

Entity Details

Entity

Command Marketing Innovations, LLC and Strategic Content Imaging, LLC

Also known as: Command Marketing Innovations and Strategic Content Imaging

Industry

Other

Official Sources

Source Evidence

Entity Name
"Command Marketing Innovations, LLC (“CMI”), and Strategic Content Imaging, LLC (“SCI”)"
Fine Amount
"pay $130,000 in penalties"
Laws Cited
"New Jersey Consumer Fraud Act (CFA)"
Laws Cited
"Health Insurance Portability and Accountability Act (“HIPAA”)"
Violation Types
"Security Breach Exposed Personal and Protected Healthcare Information"
Violation Types
"caused improper disclosure of protected health information (PHI)"

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