Comments on HHS Request for Information: Voluntary Storage of Personal Data in Preparation for Emergencies

The notion of a 21st Century vault for storing personal data for emergency use has a great deal of initial appeal. However, just below the surface lurk multiple concerns about the ability of any existing system -- or even one that could be constructed -- to ensure the public has adequate data privacy and security.

Comments to Federal Agencies Regarding the Use of Personal Medical Data by Financial Institutions

When it comes to privacy, consumer expectations and fears are most elevated for sensitive data included in medical records. A major concern is potential secondary uses of medical information. For example, a consumer may understandably be concerned that a medical condition could adversely affect the ability to get a job or a mortgage. In recent amendments to the Fair Credit Reporting Act (FCRA), Congress acted to address the discriminatory use of medical information in credit transactions.

Regarding the Privacy Implications of the Proposed National Health Information Network (NHIN)

The proposed National Health Information Network embodies a presidential mandate to bring information technology to healthcare by making complete patient records available to providers, regardless of location.

In responding to the questions asked in the RFI, we will discuss matters of privacy and security, and also whether standardization of healthcare information may ultimately be detrimental to patient treatment.

Survey Finds Most Online Pharmacies Do Not Give HIPAA Privacy Notices

Readability consultant Mark Hochhauser, Ph.D., in cooperation with the Privacy Rights Clearinghouse, conducted a survey of 50 online pharmacy web sites from mid-April through July 9, 2004. Of the 50, a scant 11 sites (22%) included a HIPAA privacy notice as required by the Department of Health and Human Services (HHS) under the federal medical privacy rule.

Pharmacies Profiting At Your Expense: Your Help Is Requested

The Privacy Rights Clearinghouse (PRC) has been in the forefront in asserting that pharmacies -- and their marketing partners, the big pharmaceutical companies -- act improperly when using the medical information in customer prescriptions to mail letters or call customers in order to sell more drugs.

If this happened to you or someone in your family, please let us know.  It could be very helpful to the outcome of the lawsuit.

Comments to Health and Human Services: Privacy and Security Rule Modification

The Heath Information Technology for Economic and Clinical Health (HITECH) Act of 2009 calls for certain changes to previously issued HHS rules regarding privacy of individuals’ medical records (the Privacy Rule), security of electronic health records (Security Rule), and enforcement of the security and privacy provisions (Enforcement Rule). The current rule proposal encompasses the HITECH modifications for all three HIPAA rules.

Disclosure Accounting: Comments Submitted to the U.S. Department of Health and Human Services, Office for Civil Rights

 In adopting the final HIPAA Privacy Rule (Privacy Rule) in 2003, OCR included a section outlining a patient’s right to receive an accounting of protected health information (PHI) disclosures. As adopted, however, the Privacy Rule includes many exceptions to the kinds of data that must be included in an accounting, one of which is that an accounting need not tell patients about disclosures made for treatment, payment, and healthcare operations.

Comments to Department of Health and Human Services re Breach Notification for Unsecured Protected Health Information

The Privacy Rights Clearinghouse (PRC) appreciates this opportunity to comment on the Department of Health and Human Services’ (HHS or Department) interim final rules regarding breach notification to individuals in the event of unauthorized use and access of protected health information. The rules, issued in coordination with the Federal Trade Commission (FTC), are mandated by Section 13402 of the Health Information Technology for Clinical Health (HITECH) A

Comments to California Department of Insurance Concerning Privacy of Personal Financial and Medical Record Information

We are pleased to see that the proposed regulations, as revised, include a number of changes that will benefit individual privacy interests. We commend the staff of the Department for efforts to balance multiple interests and their willingness to consider our concerns about loss of personal privacy.

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