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The HIPAA Journal is the leading provider of HIPAA training, news, regulatory updates, and independent compliance advice.

California Business Associate Improperly Disposed of Patient Data

Central Valley Regional Center, a Fresno, California-based state-funded provider of services to individuals with developmental disabilities, has notified patients about the recent exposure of physical documents containing their personal information. The number of affected individuals has yet to be announced.

Central Valley Regional Center employed a new vendor that provided janitorial services. In July, Central Valley Regional Center discovered that the company had been disposing of confidential documents along with regular trash. The documents had been placed in bins for confidential waste and should have been shredded. The vendor had been emptying the shredding bins and disposing of the documents in trash bags along with regular waste.

The investigation revealed that the improper disposal of documents occurred between March 2025 and July 2025 at one Central Valley Regional Center facility only. The documents likely included information such as names, addresses, dates of birth, other personal data, medical information, and Social Security numbers. The incident has been reported to law enforcement, the California Attorney General, the California State Department of Developmental Services, and all vendor contracts have been reviewed, along with policies relating to data privacy and security protocols.

Further, steps have been taken to prevent similar incidents in the future, including adding locks to all shredding bins, restricting access to shredding bits to its approved shredding service provider, revising janitorial service procedures to provide more explicit instructions on waste disposal, adding signage regarding proper waste disposal procedures, implementing routine audits to ensure compliance with internal policies and procedures, and affirming expectations regarding confidentiality and data protection with its vendors. The affected individuals have been notified by mail and have been offered identity protection services.

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Improper disposal incidents are relatively rare, yet they can result in the exposure of large amounts of PHI. The incident should serve as a warning to other healthcare organizations about the importance of providing clear instructions to service providers about their responsibilities with respect to confidential information, including service providers who may encounter physical PHI.

Author: Steve Alder is the editor-in-chief of The HIPAA Journal. Steve is responsible for editorial policy regarding the topics covered in The HIPAA Journal. He is a specialist on healthcare industry legal and regulatory affairs, and has 10 years of experience writing about HIPAA and other related legal topics. Steve has developed a deep understanding of regulatory issues surrounding the use of information technology in the healthcare industry and has written hundreds of articles on HIPAA-related topics. Steve shapes the editorial policy of The HIPAA Journal, ensuring its comprehensive coverage of critical topics. Steve Alder is considered an authority in the healthcare industry on HIPAA. The HIPAA Journal has evolved into the leading independent authority on HIPAA under Steve’s editorial leadership. Steve manages a team of writers and is responsible for the factual and legal accuracy of all content published on The HIPAA Journal. Steve holds a Bachelor’s of Science degree from the University of Liverpool. You can connect with Steve via LinkedIn or email via stevealder(at)hipaajournal.com

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