Health Privacy

Public Comments: April 2011 – WPF Files Joint Comments on California Health Information Exchanges

California has proposed regulations for health information exchange projects in the state. WPF has submitted comments encouraging more privacy protections, and we are joined in our comments by Privacy Activism and the Center for Digital Democracy. One key request in the comments is that California not allow patient consent to be waived in HIE projects. We are also requesting that California create a unified web listing of its HIE projects for increased transparency and to facilitate patient access to HIE information and policies.

WPF comments about Personal Health Records and online advertising

Health privacy — The World Privacy Forum filed comments today about how medical records and other health information is intersecting with online advertising and online activities. The WPF comments were filed with the Department of Health and Human Services in response to its request for comments on personal health records, privacy, and social media.

Public Comments: September 2010 – Joint comments on the Proposed Modifications to the HIPAA Privacy, Security, and Enforcement Rules under HITECH

In our view, the Department’s proposed changes to HIPAA regarding marketing are contrary to the law. Current law requires that paid communications for any marketing should be allowed only on an opt-in basis. We oppose the Department’s proposed regulation that would allow communications paid for by third parties who are not the entities whose product or service is being described in the communication.

WPF files two sets of key comments on HIPAA privacy rule

Health privacy and HIPAA — The World Privacy Forum filed two sets of detailed regulatory comments on recently proposed changes to HIPAA. The first comments focused on proposed changes to HIPAA in the area of marketing patient information. The proposed changes would be harmful to patient privacy, and are contrary to the law. WPF was joined in the marketing comments by the Center for Digital Democracy, Consumer Action, Consumer Federation of America, the Electronic Frontier Foundation, Privacy Activism, Privacy Rights Clearinghouse, and Privacy Times. The second set of comments WPF filed included the comments on marketing as well as on additional provisions that would be problematic if enacted.

Data broker presentation at CFP conference

Data brokers — WPF will be speaking at the CFP conference on two panels. On June 15, Pam Dixon will participate in a plenary session on data brokers. On June 16, Dixon will moderate a health care privacy panel. This panel will focus on electronic health care in the state of California and the current privacy issues in electronic health exchange.