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.

Third Privacy Roundtable - Comments Submitted to Federal Trade Commission on Sensitive Personal Information


The Privacy Rights Clearinghouse (PRC) respectfully submits the following comments to the Federal Trade Commission for its consideration in the third Privacy Roundtable, to be held March 17, 2010. 

In addressing the FTC’s question regarding what information is considered sensitive, we draw primarily from the PRC’s records of consumer complaints. Two general observations are:

  • The type of information consumers consider to be sensitive varies widely.
  • Even directory information – names, addresses, and phone numbers – is considered to be extremely sensitive to a significant number of individuals.

 

The Privacy Problems Inherent in the Smart Grid


The infrastructure that will support the Smart Grid will be capable of informing consumers of their day-to-day energy use, right down to the appliance level.  This sophisticated infrastructure has the potential to curb greenhouse gas emissions and reduce consumers’ energy bills.  However, it introduces the possibility of collecting detailed information on individual energy consumption usage and patterns within consumers’ homes, traditionally the most private of places.  Industry and regulators must take great care not to sacrifice consumer privacy in the process of developing and implementing the Smart Grid. 

 

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