On November 8, 2020, in a report called “Without Undue Delay,” Datahacks.net noted that Maze threat actors had a listing on their dedicated leak site for “Abington Reproductive Medicine.” The proof of claim that they posted, though, was not from Abington Reproductive, leaving us confused as to whether Abington Reproductive had really been a victim or not. Datahacks.net had reached out to Abington at the time, but got no responses. By January 5, 2021, there was still no statement or response to inquiries from Abington (now known as Sincera Reproductive Medicine), and no data from them were dumped by Maze or any other threat actors that appared to collaborate with Maze. Yesterday, Sincera issued a press release about the incident. It reads, in part: What Happened? On September 11, 2020, Sincera observed suspicious activity related to its internal IT systems. In response, Sincera launched an immediate response and investigation of the incident with the assistance of third-party incident response and forensic specialists. Sincera determined that an unauthorized actor had gained access to its systems and Sincera removed that access on September 13, 2020. Additionally, Sincera was able to establish that on August 10, 2020, the unauthorized actor gained access to its systems and may have exfiltrated certain patient data from its network between August 10, 2020 and September 13, 2020. Sincera subsequently conducted a thorough and comprehensive assessment of information held on its systems that this actor may have had access to and to whom that information pertained. This included the detailed and labor intensive review of all potentially impacted records which Sincera consolidated and analyzed. On April 22, 2021, Sincera confirmed the specific information potentially impacted during this incident. While Sincera is unaware of any potential misuse of data related to this incident, they have shared this information with patients in an abundance of caution. So what…. eight months after discovery, patients were notified? Given that Maze did not dump the data on their site, it may be that Maze shared or sold the data. And this is why this site keeps reiterating that in the event of a ransomware incident with exfiltration, entities should issue prompt public warnings or notifications to alert patients that their data has possibly been acquiried and may already be on the dark web where criminals acquire data to misuse. Hopefully, that is not the case with Sincera, but Datahacks.net repeats its call for HHS to provide some guidance and help on “without undue delay” so that patients are notified not just by 60 days from discovery, but even sooner.