Federal Trade Commission July 25, 2023
In the past few months, the FTC has announced case after case involving consumers’ sensitive health data, alleging violations of both Section 5 of the FTC Act and the FTC’s Health Breach Notification Rule. The privacy of health information is top of mind for consumers – and so it’s top of mind for the FTC. Companies collecting or using health data, listen up. There are a number of key messages from BetterHelp, GoodRx, Premom, Vitagene, and other FTC matters that you need to hear.
Health Privacy: The Basics
Understand the breadth of “health information.” Health information isn’t just about medications, procedures, and diagnoses. Rather, it’s anything that conveys information – or enables an inference – about a consumer’s health. Indeed,...