More Guidance, More Privacy Notices, Are You Drafting Yours for Washington?
Lexology January 22, 2024
Organizations subject to the Washington State My Health My Data Act (generally any organization with physical premises in Washington, and many organizations without it) are preparing for compliance by March 31, 2024. And should, in addition to the overall compliance requirements and immediate action items, be aware that the Washington Attorney General updated its guidance on the requirements for a consumer health privacy policy.
Section 4(1)(b) of the My Health My Data Act explicitly provides that “[a] regulated entity and a small business shall prominently publish a link to its consumer health data privacy policy on its homepage.” The Attorney General guidance now interprets this statutory requirement to mean that “the Consumer Health Privacy Policy must be a separate...