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1025-00006 · Graystone Forensics LLC · Consumer Notifications
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QUORUM INSURANCE HOLDINGS CORP.

400 Constitution Plaza, Suite 2200 Hartford, CT 06103

August 10, 2023

Margaret D. Calloway Chief Executive Officer Quorum Insurance Holdings Corp. 400 Constitution Plaza, Suite 2200 Hartford, CT 06103

James R. Whitfield 1742 Elmwood Terrace Apartment 3B Glastonbury, CT 06033

Ref: QIHC-DSN-2023-08-047291

Re: Notice of Data Security Incident

This notice is being provided to you by Quorum Insurance Holdings Corp.

Dear James R. Whitfield:

1. Purpose of This Notice

Quorum Insurance Holdings Corp. ("Quorum," "we," "us," or "our") is writing to inform you of a data security incident that may have affected your personal and financial information. We take the privacy and security of the personal information entrusted to us very seriously, and we deeply regret that this incident occurred. We are providing this notice to explain what happened, what information was involved, what we are doing in response, and what steps you can take to help protect yourself.

As part of our response, and because we understand the concern and inconvenience that a data security incident can cause, we are offering you complimentary credit monitoring and identity theft protection services for a period of twenty-four (24) months at no cost to you. We encourage you to take advantage of these services, and we have included detailed enrollment instructions below and in the enclosed materials.

This letter contains important information. Please read it carefully and in its entirety.

2. What Happened

In the ordinary course of its business operations, Quorum outsources certain claims data processing services to a third-party vendor, Palomar Data Solutions, Inc. ("Palomar"), pursuant to a written services agreement. Palomar provides data processing, claims analytics, and related administrative support services on Quorum's behalf.

On April 21, 2023, Palomar notified Quorum that it had discovered unauthorized access to Palomar's computer network systems. Upon receiving this notification, Quorum immediately engaged outside legal counsel, Calderwood & Harkness LLP, as well as a leading, nationally recognized forensic investigation firm retained under the direction of counsel, to investigate the nature and scope of the incident. Quorum also coordinated closely with Palomar and its own security advisors throughout the investigative process.

The forensic investigation determined that an unauthorized third party exploited a known vulnerability in a managed file transfer application used by Palomar. Specifically, the threat actor leveraged CVE-2023-0669, a critical vulnerability in a managed file transfer appliance, to gain unauthorized access to Palomar's network on or about March 14, 2023. This vulnerability had been publicly disclosed and was the subject of active exploitation by sophisticated threat actors targeting organizations across numerous industries.

The unauthorized access continued until approximately April 18, 2023, when Palomar's security operations team detected anomalous outbound data transfers originating from certain segments of its network and took immediate steps to contain the incident. During this approximately thirty-five (35) day window of unauthorized access, the threat actor accessed and exfiltrated certain data files that Palomar maintained in connection with the claims processing services it performed on behalf of Quorum and other clients.

It is important to note that the incident occurred within Palomar's systems and network environment. Quorum's own internal network, systems, and infrastructure were not directly compromised as a result of this incident. Nevertheless, because Palomar processed certain data on Quorum's behalf, personal information pertaining to certain Quorum policyholders, claimants, and other individuals was among the data affected.

3. What Information Was Involved

The forensic investigation was completed on July 14, 2023. A subsequent comprehensive data mining and review process, which involved the analysis of the affected data files to identify the specific individuals and data elements involved, was completed on August 4, 2023. Based on that review, we have determined that your personal information was among the data accessed and exfiltrated during the incident.

For you specifically, the following types of personal information were potentially affected:

• Full name

• Date of birth

• Social Security number

• Driver's license number

• Financial account information, which may include bank account numbers and/or payment card numbers

Please note that the specific data elements compromised may vary by individual. The categories listed above reflect the types of information identified as potentially affected with respect to your records specifically. Not all categories may apply, and in some instances, only a subset of the listed data elements may have been involved.

You are among approximately 84,619 individuals whose financial account information was involved in this incident, in addition to other personal identifiers. Because your financial information may have been compromised, we strongly encourage you to review the enhanced protective measures described in Section 5 below, particularly those related to monitoring your financial accounts and contacting your financial institutions.

4. What Quorum Is Doing

Upon learning of the incident, Quorum took immediate and comprehensive action to respond, including the following measures:

• Engaging Expert Advisors. Quorum promptly engaged outside legal counsel, Calderwood & Harkness LLP, as well as a nationally recognized forensic investigation firm retained under the direction of counsel, to conduct a thorough and independent investigation into the nature, scope, and impact of the incident. These experts worked in coordination with Palomar's own incident response team and forensic advisors.

• Containment and Scoping. Quorum worked directly with Palomar to ensure that the incident was fully contained and to understand the complete scope of the data affected. This included verifying that the vulnerability exploited by the threat actor had been remediated, that Palomar's systems were secured, and that no further unauthorized access was ongoing.

• Regulatory Notifications. Quorum has notified applicable state and federal regulators as required by law, including the Connecticut Attorney General, state attorneys general across twenty-nine (29) affected states, the Connecticut Insurance Department, and, where applicable, the U.S. Department of Health and Human Services Office for Civil Rights.

• Vendor Accountability. Quorum is holding Palomar accountable through available contractual remedies and has required Palomar to implement enhanced security measures, including but not limited to accelerated patching timelines for known vulnerabilities, deployment of advanced endpoint detection and response capabilities, mandatory independent third-party security assessments, and enhanced incident detection and notification obligations. Quorum is also evaluating all available legal remedies against Palomar in connection with this incident.

• Complimentary Credit Monitoring and Identity Theft Protection. Quorum has arranged for complimentary credit monitoring and identity theft protection services for all affected individuals for a period of twenty-four (24) months, provided by Clearfield Notification Services LLC, at no cost to you. Enrollment details and instructions are provided below and in the enclosed materials.

In addition, Quorum is conducting a comprehensive review and enhancement of its own vendor risk management program, third-party security oversight practices, and contractual data protection requirements to help prevent similar incidents from occurring in the future. These enhancements include the implementation of additional due diligence requirements for third-party vendors that process personal information on Quorum's behalf, more frequent security assessment and audit cycles, and enhanced data minimization practices.

5. What You Can Do — Steps to Help Protect Your Information

While we have no evidence at this time that your personal or financial information has been misused as a result of this incident, we recommend that you take the following steps to help protect yourself against the possibility of identity theft or fraud. Because your financial account information may have been compromised, we have included enhanced guidance specifically related to the protection of your financial accounts.

5.1 Enroll in Complimentary Credit Monitoring and Identity Theft Protection

Quorum is offering you twenty-four (24) months of complimentary credit monitoring and identity theft protection services through Clearfield Notification Services LLC, at no cost to you. These services include single-bureau credit monitoring with automated alerts for key changes to your credit file, identity theft insurance coverage, and access to identity restoration assistance from trained specialists who can help you navigate the process of restoring your identity in the event that you become a victim of identity theft.

To enroll in these complimentary services, please follow the instructions below:

• Online Enrollment: Visit the dedicated enrollment website at www.clearfieldnotify.com/quorum2023 and follow the on-screen instructions to activate your membership.

• Telephone Enrollment: Call the dedicated toll-free number at 1-855-407-2834 and a representative will assist you with enrollment.

• Your Unique Enrollment Code: QHC-2023-08-FR-49271-DW

• Enrollment Deadline: You must enroll by November 8, 2023 (90 days from the date of this notice) to take advantage of these complimentary services.

Please retain this letter and your unique enrollment code, as you will need the code to activate your membership. The enrollment code is unique to you and should not be shared with others.

5.2 Monitor Your Financial Accounts Closely

Because your financial account information — which may include bank account numbers and/or payment card numbers — may have been compromised in this incident, Quorum strongly recommends that you take the following additional steps to protect your financial accounts:

• Review your bank account statements and payment card statements carefully and regularly. Look for any unauthorized transactions, unfamiliar charges, or other suspicious activity, no matter how small. Identity thieves sometimes make small test charges before attempting larger fraudulent transactions.

• Contact your bank or financial institution immediately if you identify any unauthorized transactions. Most financial institutions have dedicated fraud departments that can assist you in investigating and resolving unauthorized charges or withdrawals. Under federal law, you may have protections that limit your liability for unauthorized transactions on your accounts, provided you report them promptly.

• Consider requesting a new account number from your bank or financial institution for any accounts whose numbers may have been compromised. Your bank can issue a new account number and transfer your existing balance and direct deposit arrangements, automatic bill payments, and other recurring transactions to the new account.

• Consider requesting a replacement payment card (debit card or credit card) with a new card number from the issuing financial institution. Most financial institutions can issue a replacement card within a few business days.

• Set up transaction alerts or notifications through your online banking portal or mobile banking application. Many banks and credit card companies allow you to receive real-time email or text message alerts for transactions exceeding a certain dollar threshold, for any transactions at all, or for other account activity such as balance changes, login attempts, or changes to account settings.

• Confirm with your financial institution that no unauthorized changes have been made to your account. This includes verifying that no changes have been made to the mailing address, email address, phone number, personal identification number (PIN), or authorized users associated with your account.

5.3 Place a Fraud Alert on Your Credit Files

You have the right to place an initial fraud alert on your credit file at no charge. A fraud alert notifies creditors and other potential lenders to take extra steps to verify your identity before granting credit in your name. This can help prevent an identity thief from opening new accounts using your personal information.

To place a fraud alert, you need only contact any one of the three major nationwide credit reporting bureaus listed below. The bureau you contact is required by law to notify the other two bureaus to place fraud alerts on your file as well.

Harborview Enterprises

Phone: 1-800-525-6285

Website: www.Harborview Enterprises.com/personal/credit-report-services

Mailing Address: Harborview Enterprises Information Services LLC, P.O. Box 105069, Atlanta, GA 30348-5069

Penrose Group

Phone: 1-888-397-3742

Website: www.Penrose Group.com/fraud

Mailing Address: Penrose Group, P.O. Box 2002, Allen, TX 75013

Penmark Enterprises

Phone: 1-800-680-7289

Website: www.Penmark Enterprises.com/fraud

Mailing Address: Quillon Solutions, P.O. Box 2000, Chester, PA 19016

An initial fraud alert lasts for one (1) year and can be renewed upon expiration. An extended fraud alert, which remains in effect for seven (7) years, is available for individuals who have been confirmed victims of identity theft and who can provide an applicable identity theft report (such as a police report or an FTC Identity Theft Report) to the credit bureau.

5.4 Place a Credit Freeze (Security Freeze)

You have the right to place a security freeze — also known as a credit freeze — on your credit report at no charge. A security freeze restricts access to your credit report, which can make it more difficult for identity thieves to open new lines of credit, loans, or other accounts in your name. Unlike a fraud alert, a security freeze actually locks your credit file so that it cannot be shared with potential creditors or other third parties without your express authorization.

To place a security freeze, you must contact each of the three major credit reporting bureaus individually:

Harborview Enterprises

Phone: 1-800-349-9960

Website: www.Harborview Enterprises.com/personal/credit-report-services/credit-freeze

Mailing Address: Harborview Enterprises Information Services LLC, P.O. Box 105788, Atlanta, GA 30348-5788

Penrose Group

Phone: 1-888-397-3742

Website: www.Penrose Group.com/freeze

Mailing Address: Penrose Group, P.O. Box 9554, Allen, TX 75013

Penmark Enterprises

Phone: 1-888-909-8872

Website: www.Penmark Enterprises.com/credit-freeze

Mailing Address: Quillon Solutions, P.O. Box 160, Woodlyn, PA 19094

Please be aware that placing a security freeze on your credit report may delay, interfere with, or otherwise prevent the timely approval of any subsequent requests or applications you make regarding new credit, loans, mortgages, insurance, government services, employment background checks, residential rental applications, or other services that require access to your credit report. If you need to allow a specific party to access your credit report while a freeze is in place, you can temporarily lift or "thaw" the freeze for a specified period of time or for a specific party. You can also permanently remove the freeze at any time. Each credit bureau will provide you with a unique personal identification number (PIN) or password that you will need to lift or remove the freeze.

5.5 Obtain Free Credit Reports

Under federal law (the Fair Credit Reporting Act), you are entitled to one free copy of your credit report every twelve (12) months from each of the three major nationwide credit reporting bureaus. We recommend that you obtain copies of your credit reports and review them carefully for any accounts, inquiries, or other activity that you do not recognize.

You may request your free annual credit reports by:

• Visiting: www.annualcreditreport.com

• Calling: 1-877-322-8228

• Writing to: Annual Credit Report Request Service, P.O. Box 105281, Atlanta, GA 30348-5281

When reviewing your credit reports, look for accounts you did not open, inquiries from creditors you did not contact, personal information that is inaccurate (such as an incorrect address or Social Security number), and any other suspicious activity. If you discover any inaccurate or suspicious information on your credit report, you have the right to dispute it directly with the credit reporting bureau.

5.6 Report Suspected Identity Theft

If you believe you are a victim of identity theft or if you detect any suspicious activity involving your personal or financial information, we recommend that you take the following steps promptly:

• File a report with the Federal Trade Commission (FTC). You can file a report online at www.identitytheft.gov or by calling the FTC's Identity Theft Hotline at 1-877-438-4338 (TTY: 1-866-653-4261). The FTC can help you create a personalized identity theft recovery plan and provide you with an FTC Identity Theft Report, which may be useful in resolving issues related to identity theft with creditors, financial institutions, and credit bureaus.

• File a police report with your local law enforcement agency. Provide as much information as possible about the suspected identity theft, including copies of any documentation you may have. Obtain a copy of the police report or, at a minimum, the report number. A police report can be helpful when dealing with creditors, financial institutions, and credit bureaus as part of the identity theft resolution process.

• Contact your state Attorney General's office. Your state Attorney General may be able to provide you with additional resources, information, and assistance related to identity theft prevention and recovery. Contact information for the Connecticut Attorney General is: Office of the Attorney General, 165 Capitol Avenue, Hartford, CT 06106; phone: 860-808-5318; website: www.ct.gov/ag.

5.7 Additional State-Specific Rights

Depending on your state of residence, you may have additional rights and protections under your state's laws. These may include the right to obtain a copy of any police report filed in connection with identity theft, the right to place or remove a security freeze or fraud alert under state-specific procedures, the right to receive additional disclosures regarding the breach, and other protections as prescribed by applicable state statutes.

Residents of certain states — including, but not limited to, Iowa, Maryland, Massachusetts, New York, North Carolina, Oregon, Rhode Island, and other states — may have specific additional rights. If applicable to your state of residence, an accompanying state-specific supplement or addendum describing these additional rights has been enclosed with this letter. Please review any enclosed supplement carefully for information specific to your state.

6. For More Information

Quorum has established a dedicated toll-free call center staffed by trained representatives to answer your questions about this incident, assist you with the enrollment process for the complimentary credit monitoring and identity theft protection services, and provide you with general guidance regarding the steps you can take to protect your personal and financial information.

Dedicated Toll-Free Number: 1-855-407-2834

Hours of Operation: Monday through Friday, 9:00 a.m. to 9:00 p.m. Eastern Time

(The dedicated call center is operated by Clearfield Notification Services LLC on behalf of Quorum Insurance Holdings Corp. and will be available for a period of twelve (12) weeks from the date of this notice.)

Dedicated Website: www.clearfieldnotify.com/quorum2023

Mailing Address for Written Inquiries: Quorum Insurance Holdings Corp. c/o Clearfield Notification Services LLC 4500 Rockside Road, Suite 210 Independence, OH 44131

When contacting the call center or submitting a written inquiry, please have this letter and your unique enrollment code available for reference.

7. Closing

Quorum sincerely regrets that this incident occurred and understands the concern and inconvenience it may cause you. Protecting the personal and financial information of our policyholders, claimants, and all individuals whose data is entrusted to our care is a responsibility we take extremely seriously. We are committed to taking all appropriate steps to help prevent a similar incident from occurring in the future, including through the enhancement of our vendor risk management practices, data security oversight procedures, and contractual protections with third-party service providers.

We encourage you to take advantage of the complimentary credit monitoring and identity theft protection services being offered and to remain vigilant in monitoring your financial accounts and credit reports over the coming months. If you have any questions or concerns, please do not hesitate to contact us using the information provided above.

Thank you for your patience and understanding.

Sincerely,

QUORUM INSURANCE HOLDINGS CORP.

By: ________

Margaret D. Calloway Chief Executive Officer

Quorum Insurance Holdings Corp. 400 Constitution Plaza, Suite 2200 Hartford, CT 06103

Enclosures:

1. Credit Monitoring and Identity Theft Protection Enrollment Instructions (Clearfield Notification Services LLC)

2. State-Specific Supplement (if applicable based on recipient's state of residence)

CONFIDENTIAL — This notice contains sensitive personal information and is intended solely for the named recipient. If you have received this notice in error, please contact us immediately at 1-855-407-2834 and securely destroy this document.