CHS Inc. Data Breach Notification
Summary
CHS Inc. notified the North Dakota Attorney General's office of an inadvertent disclosure of personal information of North Dakota residents on March 11, 2019. The disclosure involved employee and dependent data sent to a vendor via email, which was promptly deleted and confirmed as not accessed.
What changed
CHS Inc., represented by GP Law, has submitted a data breach notification to the North Dakota Attorney General's office regarding an inadvertent email disclosure of personal information of North Dakota residents. The incident occurred on February 28, 2019, when a file containing employee and dependent data, including names, addresses, birthdates, social security numbers, and health insurance information, was mistakenly sent to a CHS vendor. While CHS believes the data was not misused or compromised, the vendor confirmed deletion of the files and no unauthorized access.
This notice is being provided for transparency, although CHS does not believe it constitutes a notifiable breach under North Dakota law. CHS has notified affected residents and is implementing measures to prevent future inadvertent disclosures. The vendor has assured CHS that the data was not accessed and has deleted the files. No specific compliance deadline or penalty information is provided in this notification.
Source document (simplified)
ll;f;li lilPal Ht•t•ii'I 80 S OUTH EIGHTH STREET IDS CENTER MINNEAPOLIS, MN MAIN: 2. .FAX 2.6 .MICHAEL R. COHEN ATTORNEY DIRECT DIAL: ..DIRECT FAX: ..MICHAEL.CO H EN@G PM LAW.COM March , Office of the Attorney General C on sumer Protection and Antitrust Gateway Profe ss ional Center E Interstate Ave nu e Suite Bismarck, ND -VIA U.S. Ma il an d e mail ndag@ nd .g ov Re: No tice of Data Security Incident D ea r Sir or Madam: We represent CHS I nc . lo ca ted at Cenex Drive, Inver Grove Hei gh ts, Minnesota -. W e a re writing to notif y y our office of the ina dv ertent dis clo sure of perso na l i nformation of No rth Dakota residents. Wh il e we do not be li eve this constitutes a notifiable breach or that any of the information has b ee n misused or w ill b e used inappropriately, w e a re s ub mi tt ing this notice to be as tra ns pa rent as we can about this incident. On Februa ry , , a file with persona l i nforma ti on of CHS employ ee s and their dependents was ina dv ertently sent via email to a CHS vendor. CHS immediately be ca me aware of the mistake and that same da y p romptly notified the ve nd or. The vendor confirmed tha t t he perso na l information had no t b ee n a cc essed a nd the files with persona l i nformation were promptl y d eleted. To the best of our knowledge, the security, confidentia li ty, and integrit y o f the persona l i nformati on that was inadvertentl y d is clo se d fo r a very short peri od of time was never misused or compromised in any way. Notice to Res id ents CHS has provided written no tice of this inciden t t o all of t ho se North Da ko ta residents whose personal information was dis clo sed. What Information Wa s Involved? The information on th e fi le was ol d d ata from and was related to employee ben efi ts and included names, a dd resses, and the employee number for employ ee s, and the names, birthdates, gender, type of de pen dent, benefits en roll ed in, smoking status, life insuran ce a mounts, the health insurance plan election, and the social s ec urit y n u mb ers of dependents. What Steps did CHS Take in Response? Immediate acti on w as taken to make sure tha t t he files with a ny p ersona l i nformation were deleted. CHS has b ee n a ss ured by the v en dor that no further unauthorized disclosure or use was made of GRAY, PLANT , M OOTY, MOOTY & BE NN E TT , P.A. A FULL-SERVICE LAW FIRM MINNEAPOLIS , M N • ST. CLO UD , MN • WASHINGTON, DC FAR GO , ND WWW.GPMLAW.COM
Office of the Attorney General March , Page the data. In a dd ition, CHS is t ak ing steps to m ak e sure t ha t such in adve rtent dis clo sure do es not h appe n again. Contact Information Should y ou hav e a n y q uestions r ega rding this inci den t or notification please contact me at Very truly yo urs , .~L / Michael R. Co hen I cc: Naomi M oo re (via email) GP:--v I
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