Recent federal enforcement actions have brought home the lesson that there’s really no acceptable reason for denying a patient timely access to medical records. Last year, for example, the HHS Office for Civil Rights (OCR)...more
On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more
Many HIPAA covered entities and business associates struggle with developing and implementing a sanctions policy. What should it say, is zero-tolerance required, do we have to impose discipline in every case, etc. These are...more
The Gramm-Leach-Bliley Act (“GLBA”) was a bi-partisan regulation passed by Congress in 1999 in an attempt to update and modernize the financial industry. One component of the GLBA, its Safeguards Rule, requires financial...more
Looking for updates on government initiatives related to physicians, clinics, and physician integrity trends? Join us this October for HCCA’s Virtual Clinical Practice Compliance Conference and get insights, updates, and...more
On October 27, 2021, the FTC announced that it intends to publish (1) a final rule to amend the Standards for Safeguarding Customer Information (Safeguards Rule); (2) a supplemental notice and request for public comment on...more
On February 25th, the Federal Trade Commission (FTC) released its annual Privacy and Data Security Update, which highlights the FTC’s activities during the past year....more
Elite Dental Associates (Elite), located in Dallas, Texas has agreed to settle alleged HIPAA violations with the Office for Civil Rights (OCR) for $10,000....more
On Friday, March 15, 2019, the Federal Trade Commission released its Privacy & Data Security Update: 2018, highlighting its privacy and data security enforcement actions and other activities last year. Notable Privacy...more
For the first time in 17 years, the FTC is proposing significant increases to the information security standards which apply to those financial institutions that are regulated by the FTC and are not already subject to similar...more
he Federal Trade Commission (FTC) has focused over the course of 2018-2019 on consumer protection, data security, privacy and FinTech issues as part of its review of "Competition and Consumer Protection Issues in the 21st...more
The FTC has proposed amendments to its 2003 Safeguards Rule and 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). The proposed changes are informed by the FTC’s enforcement...more
The FTC has proposed amendments to its 2003 Safeguards Rule and the 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). ...more
Health care organizations’ lack of compliance with the data privacy and security requirements of both state laws and the Health Insurance Portability and Accountability Act (“HIPAA”) Privacy, Security and Breach Notification...more
This is the ninth installment in Hogan Lovells’ series on the California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) exempts information that is collected, processed, sold, or disclosed...more
In August 2017, the Supreme Court of India passed a judgment in the case of Justice K S Puttuswamy vs Union of India (Supreme Court of India, WRIT PETITION (CIVIL) NO 494 OF 2012), in which fundamental rights, as provided in...more
When the topic of data privacy and cyber security comes up, most people automatically think of data breaches, especially given the high-profile nature of so many of them. Breaches and hacks are certainly an issue about which...more
The Risks of Overpromising and Underperforming - Demonstrating its authority over all things cybersecurity, the Federal Trade Commission (FTC) announced that it has entered into a proposed consent order with Uber for the...more
Studies show that Americans are more worried than ever about data privacy and security on the internet. Every time you go online, you reveal a lot of information about yourself: what you browse, where you shop and what you...more
FinCEN has released guidance in the form of answers to frequently asked questions (“FAQs”) about new customer due diligence (“CDD”) requirements that became effective this month. The CDD FAQs issued on July 19 clarify new...more
In September 2015, a U.S. Department of Health and Human Services (HHS), Office of the Inspector General (OIG), report found that the Office of Civil Rights (OCR), the agency charged with ensuring compliance with the Health...more
On September 29, it was revealed that the HHS Office for Civil Rights (OCR) will commence Phase 2 of its HIPAA audit program in “early 2016.” OCR’s revelation regarding the Phase 2 audits, which had been the subject of...more
Officials at the U.S. Department of Health and Human Services Office of Civil Rights (HHS OCR) have recently selected a vendor to conduct the second wave of HIPAA audits. These so-called "Phase 2 Audits" are set to commence...more
On September 2, 2015, the U.S. Department of Health & Human Services (HHS) announced that Cancer Care Group, P.C. (CCG), a physician practice located in Indiana, agreed to pay $750,000 as part of a settlement to resolve...more
Legislation - Interprofessional National Agreement and Law on Employment Security Passed - On January 11, 2013, social partners at national level agreed to an interprofessional agreement “for a new economic and...more