News & Analysis as of

De-Identification California Consumer Privacy Act (CCPA)

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AB 713 – CCPA’s New De-Identification Amendment is Effective as of January 1 and May Require Operational Changes

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Although it received little notice, the CCPA was amended effective January 1, 2021 to clarify and modify the exemption relating to de-identified data, with particular focus on medical data.  Specifically, AB 713 amended the...more

Health Care Compliance Association (HCCA)

Report on Patient Privacy Volume 20, Number 11. Privacy Briefs: November 2020

Report on Patient Privacy 20, no. 11 (November 2020) - HHS Office of the National Coordinator (ONC) for Health Information Technology (ONC) is giving health care organizations more time to meet new rules on information...more

Knobbe Martens

Amendment to CCPA Harmonizes Data Privacy and Healthcare Information Requirements - Exemptions for de-Identified Patient...

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An amendment to the California Consumer Privacy Act (“CCPA”) was signed in September 2020. The CCPA regulates how large companies treat their customers’ personal information. However, the CCPA and healthcare information...more

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What qualifies as aggregate or de-identified information under the CCPA?

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The CCPA defines both “aggregate consumer information” and “deidentified information.” Aggregate consumer information is defined to mean “information that relates to a group or category of consumers, from which individual...more

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Is encrypted data out of the scope of the CCPA?

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In some cases yes, and in other cases no. The CCPA defines “personal information” as information that, among other things, “is capable of being associated with” a particular consumer....more

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Is it possible for data that has undergone salted-hashing to still be considered “personal information?”

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Maybe. “Salting” refers to the insertion of a random value (e.g., a number or a letter) into personal data before that data is hashed.  Whether personal information that has undergone salting and hashing is still...more

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Is it possible for data that has undergone hashing to still be considered “personal information?”

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Maybe. Hashing refers to the process of using an algorithm to transform data of any size into a unique fixed sized output (e.g., combination of numbers). ...more

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