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Insights

Briefings on privacy, cybersecurity, AI governance, and cross-border data transfers.

Data Privacy

OCR and FTC Team Up Against Transfers of Health Information through Online Tracking Technologies

The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) and the Federal Trade Commission (FTC) are teaming up to raise awareness of “serious privacy and security risks” associated with the disclosure of health information via online tracking technologies employed on websites and mobile applications, and of three agencies’ commitment…

Read insight — OCR and FTC Team Up Against Transfers of Health Information through Online Tracking Technologies
Health Privacy Laws

Washington’s My Health My Data Act Just Signed into Law: It May Have a Surprising Impact on Your Privacy Program

Introduction On April 27, 2023, Washington Governor Jay Inslee signed into law Engrossed Substitute House Bill 1155 (“My Health My Data Act” or “Act”). The Act is designed to protect not only Washington state residents’ health data, but also health data of non-residents of Washington that is processed in any manner in the state of…

Read insight — Washington’s My Health My Data Act Just Signed into Law: It May Have a Surprising Impact on Your Privacy Program
Health Privacy Laws

Cookies May be Bad for Your Health: OCR Warns Covered Entities and Business Associates of Its Broad View of HIPAA’s Applicability to Cookies, Pixels, and Other Tracking Technologies

On December 1, 2022 the Office of Civil Rights (“OCR”) at the U.S. Department of Health and Human Services issued a nonbinding guidance Bulletin on the use of online tracking technologies by covered entities and business associates (collectively, “regulated entities”) under the Health Insurance Portability and Accountability Act (“HIPAA”). The position taken by OCR in…

Read insight — Cookies May be Bad for Your Health: OCR Warns Covered Entities and Business Associates of Its Broad View of HIPAA’s Applicability to Cookies, Pixels, and Other Tracking Technologies