Court Rules
All enforcement actions
InvestigationCritical Risk

Texas AG Issues CIDs to BCBS and Conduent Over 4M Texans' Health Data Breach

Blue Cross Blue Shield of Texas and Conduent Business Services LLCFebruary 12, 2026Texas Attorney General

Consumers Affected

4,000,000

Summary

Texas Attorney General Ken Paxton issued Civil Investigative Demands to Blue Cross Blue Shield of Texas and Conduent Business Services LLC as part of an investigation into a massive data breach at Conduent that exposed the protected health information of approximately four million Texans. The breach occurred between October 21, 2024 and January 13, 2025, affecting Texas Medicaid recipients and other residents. The AG's office is investigating the security failures and compliance with Texas law.

Contract Impact

In-house legal teams should review all contracts with third-party service providers handling protected health information or other sensitive consumer data, ensuring they include robust data security safeguard requirements, clear breach notification timelines, and liability provisions for security failures. Contracts with vendors processing health data should specifically require compliance with applicable state and federal health privacy laws, regular security audits, and incident response protocols. Additionally, teams should verify that vendor agreements include provisions for prompt notification of any unauthorized access to data, as well as indemnification for breaches caused by vendor negligence.

Contract Search Terms

protected health information (PHI)data security safeguardsthird-party vendor data protectionbreach notification requirementssystem security audithealth data complianceincident response planvendor security assessment

Violation Types

Entity Details

Entity

Blue Cross Blue Shield of Texas and Conduent Business Services LLC

Also known as: Blue Cross Blue Shield and Conduent

Industry

Insurance

Official Sources

Source Evidence

Entity Name
"Blue Cross Blue Shield of Texas (“BCBS”) and Conduent Business Services LLC (“Conduent”)"
Consumers Affected
"exposed the sensitive personal data of approximately four million Texans"
Violation Types
"breach of Conduent’s system security that occurred between October 21, 2024 through January 13, 2025. During the breach, an unauthorized third-party accessed the protected health information of Texas residents, including Texas Medicaid recipients"
Jurisdiction
"Attorney General Ken Paxton"
Event Type
"part of the investigation of the Conduent data breach"
Entity Industry
"any insurance giant cut corners"

Related Enforcement Actions

TX

Meta Platforms, Inc.

$1.0B

Texas Attorney General Ken Paxton secured a historic settlement with Meta Platforms, Inc. requiring Meta to pay over $1 billion and implement significant new safeguards to protect children online. The settlement includes stricter age-assurance measures, a daily two-hour limit for teen users, default disabling of notifications during school hours, hidden likes/reactions, and a nighttime access mode restricting features for children.

TX

Primal Kitchen, Siete Foods, Chosen Foods

Texas Attorney General Ken Paxton launched an industry-wide investigation into companies marketing avocado oil products that may contain undisclosed seed oils. Civil Investigative Demands were issued to Primal Kitchen, Siete Foods, and Chosen Foods, with more companies expected to be investigated for potential violations of the Texas Deceptive Trade Practices Act.

TX

WK Kellogg Co. and General Mills Inc.

Attorney General Ken Paxton secured settlements with WK Kellogg Co. and General Mills Inc. requiring the removal of synthetic dyes from cereals served in schools. The companies have already removed these dyes from K-12 cereals, with full removal from all products by the end of 2027.

TX

American Academy of Pediatrics

Texas Attorney General Ken Paxton launched an investigation into the American Academy of Pediatrics (AAP) over concerns that the organization may be promoting and recommending childhood vaccines for financial gain. The AAP has been issued a Civil Investigative Demand to determine the basis of its vaccine recommendations and whether they are influenced by financial incentives from pharmaceutical donors.

TX

Frito Lay, Flora Food Group, and ACH Foods

Texas Attorney General Ken Paxton announced an investigation into major food manufacturers, including Frito Lay, Flora Food Group, and ACH Foods, over misleading 'heart healthy' labeling. The investigation will examine whether their advertising practices violate the Texas Deceptive Trade Practices Act by misrepresenting the health value of their products. Civil Investigative Demands have been issued to these companies.

TX

Lone Star Pups, LLC

Texas Attorney General Ken Paxton opened an investigation into Lone Star Pups, LLC for misleading consumers about the origin and veterinary care of puppies sold online. The company allegedly misrepresents breeder certifications and a '10 Year Health Guarantee' with restrictive fine print. The investigation focuses on potential violations of the Texas Deceptive Trade Practices Act.