U.S. privacy developments are moving quickly, but health data privacy is racing forward. Companies that come into contact with consumers’ health data need to track and respond to a variety of developments. Most notably, these include Washington’s My Health My Data (MHMD) Act, a similar law in Nevada, ​“sensitive data” and ​“sensitive personal information” requirements under comprehensive state privacy laws, and FTC enforcement actions and guidance that assert that a broad range of health data is sensitive. How a company responds to these developments is likely to be iterative given the lack of clarity or harmonization with these requirements, and substantial resources required to implement changes.

https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/health-data-privacy-what-were-hearing

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