The Federal Trade Commission (FTC) has a long-standing habit of creating legal obligations through blog posts. Recent communications from the FTC by way of its Office of Technology Blog evidence an aggressive expectation...more
Although it received little notice, the CCPA was amended effective January 1, 2021 to clarify and modify the exemption relating to de-identified data, with particular focus on medical data. Specifically, AB 713 amended the...more
De-identification of data refers to the process used to prevent personal identifiers from being connected with information. The FTC indicated in its 2012 report Protecting Consumer Privacy in an Era of Rapid Change:...more
The HHS Office of Civil Rights (OCR) recently released guidance intended to assist covered entities in understanding what de-identification is, the general process by which de-identified information can be created, and the...more
On November 26, 2012, the Department of Health and Human Services Office for Civil Rights (“OCR”) published a thirty-two page document titled “Guidance Regarding Methods for De-identification of Protected Health Information...more
On November 26, 2012, the Department of Health and Human Services Office for Civil Rights (OCR) released long-overdue guidance on how covered entities subject to the Health Insurance Portability and Accountability Act (HIPAA)...more