The World Privacy Forum commented on an important proposal to make changes to the existing rules regarding the confidentiality of alcohol and drug abuse patient records. The proposal is from the Substance Abuse and Mental Health Services Administration (SAMHSA), part of the US Department of Health and Human Services. These proposed rule changes are important, as the current
The World Privacy Forum filed comments with the U.S. Department of Commerce in response to its Request for Comments about big data, privacy, and the Consumer Privacy Bill of Rights. The White House Big Data report recognized that Big Data “raises considerable questions about how our framework for privacy protection applies in a big data ecosystem” and has the potential to “eclipse longstanding civil rights protections in how personal information is used in housing, credit, employment, health, education, and the marketplace.” This is among our concerns as well, and our comments focused on understanding big data’s benefits while drawing attention to where there are significant privacy risks that need to be addressed.
The World Privacy Forum’s recent public comments to the White House regarding Big Data focus on using a foundation of Fair Information Principles to address issues connected to bias, error, and privacy regarding big data as applied to vulnerable populations. The comments also discuss large medical research data sets, and stress the importance of applying
WPF filed comments with the Presidential Commission for the Study of Bioethics today urging the Commission to recognize the need for enhanced genetic privacy protections in a digital world. WPF noted that “The increasing identifiability of genetic data presents major privacy issues for research activities that must be acknowledged and addressed.” WPF suggested four key ways that Certificate of Confidentiality programs could be enhanced for privacy protection, and urged the Commission to speak out about the importance of protecting patient privacy in research activities involving genetic information. “The Commission should advocate providing patients with reasonable controls over research uses of their data as electronic records develop and spread throughout the health care system.” Public comments may be submitted to the Commission until May 25, 2012.
Common Rule | Health Privacy — The World Privacy Forum filed extensive comments with the US Department of Health and Human Services about its proposed changes regarding the rules governing human subject medical research. In the comments, WPF noted that the HHS approach to privacy for research subjects was incomplete and did not use all Fair Information Practices. WPF strongly urged HHS to revise its proposal on a number of issues, including consent and the use of biospecimens in research. The World Privacy Forum is urging HHS to acknowledge that the realm of health data that is truly non-identifiable has shrunken remarkably, for example, biospecimens with DNA cannot be considered non-identifiable anymore. “In our comments, we are requesting that HHS give individuals the opportunity to make choices about the use of their own health data and specimens,” said Executive director Pam Dixon. WPF also stated in its comments that “A central database with identifiable information about participants in human subjects research is a terrible idea.” (See p. 21 of WPF comments.)