News & Analysis as of

De-Identification Personal Information

Wiley Rein LLP

CFPB Proposes to Expand Reach of Fair Credit Reporting Act to “Data Brokers” and Beyond

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On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (NPRM or Proposed Rule) that proposes to significantly expand the scope of the Fair Credit Reporting Act (FCRA) to...more

Goodwin

China is Entering a New Era in Data Protections

Goodwin on

On November 1, 2021, the Personal Information Protection Law of the People’s Republic of China (the “PRC”) (the “Personal Information Protection Law”) went into effect, two months after the Data Security Law of the PRC (the...more

Health Care Compliance Association (HCCA)

Report on Patient Privacy Volume 20, Number 11. Privacy Briefs: November 2020

Report on Patient Privacy 20, no. 11 (November 2020) - HHS Office of the National Coordinator (ONC) for Health Information Technology (ONC) is giving health care organizations more time to meet new rules on information...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Canada Update: Québec Proposes Privacy Bill With Teeth, Ontario Ponders Requirements for Data Collection by Private Bodies

On June 12, 2020, Québec’s then minister of justice, Sonia LeBel, tabled in the National Assembly Bill 64, An Act to modernize legislative provisions as regards the protection of personal information. Bill 64’s purpose is...more

Knobbe Martens

Amendment to CCPA Harmonizes Data Privacy and Healthcare Information Requirements - Exemptions for de-Identified Patient...

Knobbe Martens on

An amendment to the California Consumer Privacy Act (“CCPA”) was signed in September 2020. The CCPA regulates how large companies treat their customers’ personal information. However, the CCPA and healthcare information...more

BCLP

What qualifies as aggregate or de-identified information under the CCPA?

BCLP on

The CCPA defines both “aggregate consumer information” and “deidentified information.” Aggregate consumer information is defined to mean “information that relates to a group or category of consumers, from which individual...more

BCLP

Is encrypted data out of the scope of the CCPA?

BCLP on

In some cases yes, and in other cases no. The CCPA defines “personal information” as information that, among other things, “is capable of being associated with” a particular consumer....more

BCLP

Is it possible for a token to still be considered “personal information?”

BCLP on

Maybe. “Tokenization” refers to the process by which you replace one value (e.g., a credit card number) with another value that would have “reduced usefulness” for an unauthorized party (e.g., a random value used to...more

BCLP

Is it possible for data that has undergone salted-hashing to still be considered “personal information?”

BCLP on

Maybe. “Salting” refers to the insertion of a random value (e.g., a number or a letter) into personal data before that data is hashed.  Whether personal information that has undergone salting and hashing is still...more

BCLP

Is it possible for data that has undergone hashing to still be considered “personal information?”

BCLP on

Maybe. Hashing refers to the process of using an algorithm to transform data of any size into a unique fixed sized output (e.g., combination of numbers). ...more

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