BHG Holdings, LLC dba Behavioral Health Group Provides Notice of Data Security Incident

 

BHG Holdings, LLC dba Behavioral Health Group (“BHG”) is committed to maintaining the privacy and security of the information that it maintains. BHG recently experienced a data security incident impacting certain personal and/or protected health information it maintains. 

Upon learning of this issue, BHG immediately took steps to secure its network and mitigate against any additional harm. BHG also promptly launched an investigation in consultation with outside cybersecurity professionals who regularly investigate and analyze these types of situations to determine whether any sensitive data had been compromised as a result of the incident. BHG’s investigation determined that the unauthorized individual(s) potentially removed certain files and folders from portions of its network on December 5, 2021. On June 22, 2022, following an extensive review and analysis of the data at issue, BHG determined that certain files and folders that may have been accessed or acquired contained identifiable personal and/or protected health information for individuals who received services from BHG, including the individuals’ full name, Social Security number, driver’s license or state identification number, financial account information, payment card information, passport, biometrics, health insurance information and/or medical information including medical diagnosis and treatment, medication information, dates of service, and/or medical record number. This incident does not affect all patients of BHG and not all information was included for all individuals. 

BHG has no evidence to suggest that any information has been misused. However, out of an abundance of caution, on July 27, 2022, BHG provided notification to individuals whose information may have contained in the impacted files and folders. Notified individuals have been provided with best practices to protect their information and have been reminded to remain vigilant in reviewing financial account statements on a regular basis for any fraudulent activity. Notified individuals should also review the explanation of benefits statements that they receive from their health insurance providers and follow up on any items not recognized. For those individuals whose Social Security numbers were involved, complimentary credit monitoring has been offered. Additional safeguards are provided below under “Other Important Information”. 

At BHG, protecting the privacy of personal information is a top priority. BHG is committed to maintaining the privacy of personal information in its possession and has taken many precautions to safeguard it. In response to this incident, BHG has strengthened it network and implemented additional security improvements recommended by third-party cyber security experts. These include resetting account passwords and strengthening its password security policies, implementing multi-factor authentication for network access, upgrading its endpoint detection software, integration of a 24/7 third-party security monitoring service and coordinating additional employee training related to network security and threat detection.

For individuals who have questions or need additional information regarding this incident, or to determine if they are impacted, BHG has set up a dedicated toll-free response line for individuals to ask questions. The response line can be contacted at 833-940-2473 and is available Monday through Friday, 9:00 a.m. to 9:00p.m. Eastern Time.

 

– OTHER IMPORTANT INFORMATION –

 

Placing a Fraud Alert on Your Credit File.

We recommend that you place an initial one-year “Fraud Alert” on your credit files, at no charge. A fraud alert tells creditors to contact you personally before they open any new accounts. To place a fraud alert, call any one of the three major credit bureaus at the numbers listed below. As soon as one credit bureau confirms your fraud alert, they will notify the others.

 

Equifax

P.O. Box 105069

Atlanta, GA 30348-5069

https://www.equifax.com/personal/credit-report-services/credit-fraud-alerts/

(800) 525-6285

Experian

P.O. Box 9554

Allen, TX 75013

https://www.experian.com/fraud/center.html

(888) 397-3742

TransUnion

Fraud Victim Assistance Department

P.O. Box 2000

Chester, PA 19016-2000

https://www.transunion.com/fraud-alerts

(800) 680-7289

 

Consider Placing a Security Freeze on Your Credit File. 

If you are very concerned about becoming a victim of fraud or identity theft, you may request a “Security Freeze” be placed on your credit file, at no charge. A security freeze prohibits, with certain specific exceptions, the consumer reporting agencies from releasing your credit report or any information from it without your express authorization. You may place a security freeze on your credit report by contacting all three nationwide credit reporting companies at the numbers below and following the stated directions or by sending a request in writing, by mail, to all three credit reporting companies:

 

Equifax Security Freeze

P.O. Box 105788

Atlanta, GA 30348-5788

https://www.equifax.com/personal/credit-report-services/credit-freeze/   

(888) 298-0045

Experian Security Freeze

P.O. Box 9554

Allen, TX 75013

http://experian.com/freeze

(888) 397-3742

TransUnion Security Freeze

P.O. Box 160

Woodlyn, PA 19094

https://www.transunion.com/credit-freeze

(888) 909-8872

 

 In order to place the security freeze, you’ll need to supply your name, address, date of birth, Social Security number and other personal information. After receiving your freeze request, each credit reporting company will send you a confirmation letter containing a unique PIN (personal identification number) or password. Keep the PIN or password in a safe place. You will need it if you choose to lift the freeze.

If your personal information has been used to file a false tax return, to open an account or to attempt to open an account in your name or to commit fraud or other crimes against you, you may file a police report in the City in which you currently reside.

If you do place a security freeze prior to enrolling in the credit monitoring service as described above, you will need to remove the freeze in order to sign up for the credit monitoring service. After you sign up for the credit monitoring service, you may refreeze your credit file.  

Obtaining a Free Credit Report. 

Under federal law, you are entitled to one free credit report every 12 months from each of the above three major nationwide credit reporting companies. Call 1-877-322-8228 or request your free credit reports online at www.annualcreditreport.com. Once you receive your credit reports, review them for discrepancies. Identify any accounts you did not open or inquiries from creditors that you did not authorize. Verify all information is correct. If you have questions or notice incorrect information, contact the credit reporting company.

Additional Helpful Resources.

Even if you do not find any suspicious activity on your initial credit reports, the Federal Trade Commission (FTC) recommends that you check your credit reports periodically. Checking your credit report periodically can help you spot problems and address them quickly.

If you find suspicious activity on your credit reports or have reason to believe your information is being misused, call your local law enforcement agency and file a police report. Be sure to obtain a copy of the police report, as many creditors will want the information it contains to absolve you of the fraudulent debts. You may also file a complaint with the FTC by contacting them on the web at www.ftc.gov/idtheft, by phone at 1-877-IDTHEFT (1-877-438-4338), or by mail at Federal Trade Commission, Consumer Response Center, 600 Pennsylvania Avenue, NW, Washington, DC 20580. Your complaint will be added to the FTC’s Identity Theft Data Clearinghouse, where it will be accessible to law enforcement for their investigations. In addition, you may obtain information from the FTC about fraud alerts and security freezes. 

If this notice letter states that your financial account information and/or credit or debit card information was impacted, we recommend that you contact your financial institution to inquire about steps to take to protect your account, including whether you should close your account or obtain a new account number.

 

Protecting Your Medical Information. 

We have no evidence that your medical information involved in this incident was or will be used for any unintended purposes. However, the following practices can provide additional safeguards to protect against medical identity theft.

  • Only share your health insurance cards with your health care providers and other family members who are covered under your insurance plan or who help you with your medical care.
  • Review your “explanation of benefits statement” which you receive from your health insurance company. Follow up with your insurance company or care provider for any items you do not recognize. If necessary, contact the care provider on the explanation of benefits statement and ask for copies of medical records from the date of the potential access (noted above) to current date.
  • Ask your insurance company for a current year-to-date report of all services paid for you as a beneficiary. Follow up with your insurance company or the care provider for any items you do not recognize.

Iowa Residents: You may contact law enforcement or the Iowa Attorney General’s Office to report suspected incidents of identity Theft: Office of the Attorney General of Iowa, Consumer Protection Division, Hoover State Office Building, 1305 East Walnut Street, Des Moines, IA 50319, www.iowaattorneygeneral.gov, Telephone: (515) 281-5164.

New York Residents: You may obtain information about preventing identity theft from the New York Attorney General’s Office: Office of the Attorney General, The Capitol, Albany, NY 12224-0341; https://ag.ny.gov/consumer-frauds-bureau/identity-theft; Telephone: 800-771-7755.

Maryland Residents: You may obtain information about avoiding identity theft from the Maryland Attorney General’s Office: Office of the Attorney General of Maryland, Consumer Protection Division, 200 St. Paul Place, Baltimore, MD 21202, www.oag.state.md.us/Consumer, Telephone: 1-888-743-0023.

North Carolina Residents: You may obtain information about preventing identity theft from the North Carolina Attorney General’s Office: Office of the Attorney General of North Carolina, Department of Justice, 9001 Mail Service Center, Raleigh, NC 27699-9001, www.ncdoj.gov/, Telephone: 877-566-7226.

Oregon Residents: You may obtain information about preventing identity theft from the Oregon Attorney General’s Office: Oregon Department of Justice, 1162 Court Street NE, Salem, OR 97301-4096, www.doj.state.or.us/, Telephone: 877-877-9392.

New Mexico Residents: You have rights under the federal Fair Credit Reporting Act (FCRA). These include, among others, the right to know what is in your file; to dispute incomplete or inaccurate information; and to have consumer reporting agencies correct or delete inaccurate, incomplete, or unverifiable information. For more information about the FCRA, please visit www.consumer.ftc.gov/articles/pdf-0096-fair-credit-reporting-act.pdf or www.ftc.gov.

In Addition, New Mexico Consumers Have the Right to Obtain a Security Freeze or Submit a Declaration of Removal 

As noted above, you may obtain a security freeze on your credit report to protect your privacy and ensure that credit is not granted in your name without your knowledge. You may submit a declaration of removal to remove information placed in your credit report as a result of being a victim of identity theft. You have a right to place a security freeze on your credit report or submit a declaration of removal pursuant to the Fair Credit Reporting and Identity Security Act.

The security freeze is designed to prevent credit, loans, and services from being approved in your name without your consent. When you place a security freeze on your credit report, you will be provided with a personal identification number, password, or similar device to use if you choose to remove the freeze on your credit report or to temporarily authorize the release of your credit report to a specific party or parties or for a specific period of time after the freeze is in place. To remove the freeze or to provide authorization for the temporary release of your credit report, you must contact the consumer reporting agency and provide all of the following: 

  1. The unique personal identification number, password, or similar device provided by the consumer reporting agency;
  2. Proper identification to verify your identity; and
  3. Information regarding the third party or parties who are to receive the credit report or the period of time for which the credit report may be released to users of the credit report.

A consumer reporting agency that receives a request from a consumer to lift temporarily a freeze on a credit report shall comply with the request no later than three business days after receiving the request. As of September 1, 2008, a consumer reporting agency shall comply with the request within fifteen minutes of receiving the request by a secure electronic method or by telephone.

A security freeze does not apply in all circumstances, such as where you have an existing account relationship and a copy of your credit report is requested by your existing creditor or its agents for certain types of account review, collection, fraud control, or similar activities; for use in setting or adjusting an insurance rate or claim or insurance underwriting; for certain governmental purposes; and for purposes of prescreening as defined in the federal Fair Credit Reporting Act.

 If you are actively seeking a new credit, loan, utility, telephone, or insurance account, you should understand that the procedures involved in lifting a security freeze may slow your own applications for credit. You should plan ahead and lift a freeze, either completely if you are shopping around or specifically for a certain creditor, with enough advance notice before you apply for new credit for the lifting to take effect. You should contact a consumer reporting agency and request it to lift the freeze at least three business days before applying. As of September 1, 2008, if you contact a consumer reporting agency by a secure electronic method or by telephone, the consumer reporting agency should lift the freeze within fifteen minutes. You have a right to bring a civil action against a consumer reporting agency that violates your rights under the Fair Credit Reporting and Identity Security Act.

To place a security freeze on your credit report, you must send a request to each of the three major consumer reporting agencies: Equifax, Experian, and TransUnion. You may contact these agencies using the contact information provided above.

Rhode Island Residents: You may contact law enforcement, such as the Rhode Island Attorney General’s Office, to report incidents of identity theft or to learn about steps you can take to protect yourself from identity theft. You can contact the Rhode Island Attorney General at: Rhode Island Office of the Attorney General, 150 South Main Street, Providence, RI 02903, www.riag.ri.gov, 401-274-4400.  

As noted above, you may obtain a security freeze on your credit report to protect your privacy and ensure that credit is not granted in your name without your knowledge. You have a right to place a “security freeze” on your credit report pursuant to chapter 48 of title 6 of the Identity Theft Prevention Act of 2006.

The security freeze is designed to prevent credit, loans, and services from being approved in your name without your consent. When you place a security freeze on your credit report, within five (5) business days you will be provided a personal identification number or password to use if you choose to remove the freeze on your credit report or to temporarily authorize the release of your credit report for a specific period of time after the freeze is in place. To provide that authorization, you must contact the consumer reporting agency and provide all of the following: 

  1. The unique personal identification number or password provided by the consumer reporting agency.
  2. Proper identification to verify your identity.
  3. The proper information regarding the period of time for which the report shall be available to users of the credit report.

A consumer reporting agency that receives a request from a consumer to temporarily lift a freeze on a credit report shall comply with the request no later than three (3) business days after receiving the request.

A security freeze does not apply to circumstances where you have an existing account relationship and a copy of your report is requested by your existing creditor or its agents or affiliates for certain types of an account review, collection, fraud control, or similar activities. 

If you are actively seeking a new credit, loan, utility, telephone, or insurance account, you should understand that the procedures involved in lifting a security freeze may slow your own applications for credit. You should plan ahead and lift a freeze -- either completely, if you are shopping around, or specifically for a certain creditor -- with enough advance notice before you apply for new credit for the lifting to take effect. 

You have a right to bring a civil action against someone who violates your rights under the credit reporting laws. The action can be brought against a consumer reporting agency or a user of your credit report.

To place a security freeze on your credit report, you must send a request to each of the three major consumer reporting agencies: Equifax, Experian, and TransUnion. These agencies can be contacted using the contact information provided above. 

In order to request a security freeze, you may need to provide the following information:

  1. Your full name (including middle initial as well as Jr., Sr., II, III, etc.);
  2. Social Security number;
  3. Date of birth;
  4. Complete address;
  5. Prior addresses;
  6. Proof(s) of identification (state driver’s license or ID card, military identification, birth certificate, etc.);
  7. If you are a victim of identity theft, a copy of either the police report, investigative report, or complaint to a law enforcement agency concerning identity theft. 

There were 900 Rhode Island residents impacted by this incident.