WPF urges HHS National Vaccine Advisory Committee to extend privacy protections of vaccination information

In public testimony September 15, 2021, WPF’s Executive Director urged the Department of Health and Human Services National Vaccine Advisory Committee Committee to establish broadened protections for covid-19 vaccination data, including extending the existing CDC Guidance (from May 2021) prohibiting commercial marketing use of vaccination registration information or other vaccination data.

The intersection between HIPAA privacy regulations and public health data is labyrinthine and messy at the best of times. But now, due to the extraordinary circumstances of the pandemic, broader protections for vaccination data are necessary. Protections for this information are important because the lack of transparency and the overall uncertainty around data utilization — including in digital proof-of-vaccine systems — can act to undermine trust in the public health system.

From WPF’s written comments to the Committee:

“There are rapid developments in COVID-19 vaccine data systems, such as the build out of the Vaccine Administration Management System (VAMS), the upgrading of the Immunization Information System (IIS), and now a new ecosystem of vaccine credentialing subsystems. There should be no place or opportunity in this new ecosystem for the commercial marketing use of vaccine recipient data.”

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Posted September 15, 2021 in COVID-19, Health Privacy, Health Records, Public Health

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