In late 2019, the Organization discovered that an employee with one of its independent agencies emailed several documents containing client personal information to his personal email account. The Organization also discovered that this individual might have taken physical documents containing client personal information. The Organization reported that, at the time, the individual was an employee with the independent agency and thus a representative of the Organization and while the emailing was inappropriate, the Organization felt there was minimal risk to the individuals involved. The individual?s employment with the independent agency ended in December 2019. On September 2, 2020, the Organization discovered that the individual sent additional emails to his personal email account between October 1, 2019 and December 31, 2019, which contained personal information of the Organization?s clients.

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