In a recent blog post, the FTC again cautioned entities that hashing data does not make that data anonymous. Hashing is a process that takes a particular input, such as a phone number or email address, and uses a mathematical...more
Financial services companies beware: the new state privacy laws exemption are not uniform. To recap, there are privacy laws in 12 states: California, Colorado, Connecticut, Florida, Indiana, Iowa, Montana, Oregon, Tennessee,...more
The FTC and OCR at HHS are continuing to scrutinize the use of tracking technologies that may reveal information about a person’s health or health status. Both agencies recently sent a letter to a reported 130 hospitals and...more
7/25/2023
/ Data Collection ,
Data Privacy ,
Department of Health and Human Services (HHS) ,
Digital Health ,
Electronic Medical Records ,
Federal Trade Commission (FTC) ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
OCR ,
Popular ,
Privacy Laws ,
Section 5 ,
Telehealth ,
Tracking Systems
With six months before the first of the new US state general privacy laws go into effect, there are several steps companies can take now to begin to prepare. Unfortunately there are some parts of compliance that will be...more
The Colorado AG’s office recently released pre-rulemaking considerations for the Colorado Privacy Act (CPA). The office is seeking informal public feedback on a series of topics. While the AG listed eight specific topics for...more
n December 22, 2021, the Food and Drug Administration (FDA) issued a draft guidance for sponsors, investigators, and other interested parties on using digital health technologies (DHT) to acquire data remotely from...more
1/7/2022
/ Clinical Trials ,
Comment Period ,
Coronavirus/COVID-19 ,
Data Collection ,
Data Privacy ,
Digital Health ,
Food and Drug Administration (FDA) ,
Investigations ,
Medical Devices ,
New Guidance ,
Technology Sector
Google Play’s “data safety form” is now live. Developers can now submit the form for early review and feedback. Starting in April 2022, Google will require this label and a privacy policy for all new and existing apps. This...more
New York City recently enacted a biometric ordinance that is set to come into effect July 9, 2021. With this ordinance, NYC joins other cities (like Portland) in regulating the use of biometric information. The ordinance may...more
Utah recently amended its breach notice law to provide certain defenses to companies who suffer a data breach. It is now the second state, after Ohio, to include such provisions. Specifically, entities that create and...more
Many digital health app developers offering health and wellness solutions directly to consumers may find themselves in a space unregulated by the Health Insurance Portability and Accountability Act (“HIPAA”). While...more
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The Network Advertising Initiative, which provides guidance to advertisers who engage in personalized advertising, updated its Code of Conduct (2020 Code) earlier this year to address, inter alia, data collected offline and...more
Joining Vermont, California will now require data brokers to register with the California Attorney General. The law was signed October 11, 2019. It applies to companies that “knowingly” collect and sell personal information...more
10/14/2019
/ Amended Legislation ,
California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Brokers ,
Data Collection ,
E-Commerce ,
Governor Newsom ,
Privacy Laws ,
Registration Requirement ,
State Attorneys General ,
State Data Privacy Laws