Lexology December 19, 2022
On December 1, 2022, the Office for Civil Rights at the U.S. Department of Health and Human Services (“HHS”) released a Bulletin on the obligations of HIPAA covered entities and business associates under the HIPAA Privacy, Security, and Breach Notification Rules when using online tracking technologies.
In the Bulletin, HHS warned, for example, that some HIPAA-regulated entities may be sharing electronic protected health information (“PHI”) with online tracking technology vendors in violation of the HIPAA Privacy Rule. Tracking technologies used by regulated entities may have access to PHI, such as an individual’s IP address, medical record number, home...
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