Court Rules
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NJ AG Fines EmblemHealth $100K for Mailing Labels with SSNs

EmblemHealth, Inc.December 10, 2018New Jersey Attorney General

Penalty Amount

$100,000

Consumers Affected

6,443

Summary

EmblemHealth, Inc. settled with the New Jersey Attorney General over a 2016 data breach where Medicare Health Insurance Claim Numbers (containing Social Security numbers) were improperly disclosed on mailing labels to over 81,000 customers, including 6,443 in New Jersey. The company agreed to pay a $100,000 civil penalty and implement compliance reforms including ceasing use of HICNs with SSNs, enhancing employee training, and notifying the state of future breaches.

Remedy

EmblemHealth must pay a $100,000 penalty, discontinue using HICNs that include SSNs for customer identification in mailings, implement formal responsibility transfer and privacy training for employees, and report any future breaches affecting New Jersey customers to the Division of Consumer Affairs for three years.

Monetary PenaltyCompliance ProgramReporting Requirements

Contract Impact

In-house legal teams should review vendor agreements and customer-facing documents (e.g., evidence of coverage mailings, privacy notices). Specifically, scrutinize clauses governing data sharing, data minimization, and instructions for third-party vendors to ensure sensitive identifiers like HICNs/SSNs are never included on physical mailings. Review employee training obligations and breach notification protocols to ensure they meet or exceed state requirements (like the NJ Identity Theft Prevention Act) and HIPAA standards. Contracts may need amendments to mandate explicit data field removal instructions for vendors, prohibit the inclusion of full SSNs on any mailed materials, and require immediate state notification for any unauthorized disclosure of health or SSN data.

Contract Search Terms

Social Security numberMedicare Health Insurance Claim NumberHICNdata minimizationvendor data handlingmailing label disclosureemployee trainingbreach notificationdata processing addendumsensitive personal information

Laws Cited

New Jersey Identity Theft Prevention ActNew Jersey Consumer Fraud ActHealth Insurance Portability and Accountability Act (HIPAA)

Violation Types

Entity Details

Entity

EmblemHealth, Inc.

Also known as: EmblemHealth

Industry

Healthcare

Official Sources

Source Evidence

Entity Name
"health insurance provider EmblemHealth, Inc."
Fine Amount
"pay the State a $100,000 civil penalty"
Laws Cited
"violated the New Jersey Identity Theft Prevention Act, the New Jersey Consumer Fraud Act and the Health Insurance Portability and Accountability Act (HIPAA)."
Violation Description
"the label affixed to the mailing improperly included each customer’s HICN, which incorporates the nine digits of the customer’s Social Security number"

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