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An employee at health facility A reported to the privacy department that his iPad was stolen. IS determined that the iPad was password protected, encrypted,

An employee at health facility A reported to the privacy department that his iPad was stolen. IS determined that the iPad was password protected, encrypted, and that the iPad contained 4,000 health facility A patients' first and last names, medical record numbers (MRNs), and medical history information.  IS cannot ascertain whether the person in receipt of the stolen laptop has actually viewed any of the patients' health information. Health facility A is a licensed facility.

  1. Was there a privacy breach?
  1. Is the breach reportable under California and/or federal regulations? [indicate and explain if any regulatory exceptions apply (e.g. HIPAA breach exceptions).]
  1. To whom should the breach be reported (if applicable)?
  1. What recommendations do you have for the Covered Entity as a result of the potential breach (e.g. internal policies, employee sanctions, etc.)?

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