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FTC Updates Health Breach Notification Rule

On July 1, 2024, the amendments to the Health Breach Notification Rule (HBNR) went into effect. First promulgated in 2009, the HBNR applies to vendors of personal health records — entities that are not covered by the Health...more

So, What’s “Consumer Health Data,” Anyway?

The U.S. privacy landscape has changed rapidly over the past few years. But the most significant recent changes relate to “consumer health data” — health information about identified or identifiable consumers that falls...more

Zombie PHR Breach Rule Rises From the Dead

Yesterday, the FTC issued a policy statement announcing a new interpretation of the FTC’s 10-year-old “Personal Health Record Breach Notification Rule.” As the FTC acknowledges, this rule has never been enforced by the FTC....more

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