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ARTICLE · 01 NOVEMBER 2024

Preparing For Increased Regulatory Enforcement In Privacy, Cybersecurity And AI

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In 2024, the Federal Trade Commission (FTC) has continued its public data privacy and security enforcement actions. Many of these actions have addressed alleged violations relating to health, location, and biometric data...

United StatesTechnology
Rebecca R. Valentino
Rebecca R. Valentino
Dorian W. Simmons
Dorian W. Simmons

In 2024, the Federal Trade Commission (FTC) has continued its public data privacy and security enforcement actions. Many of these actions have addressed alleged violations relating to health, location, and biometric data practices. Below is a summary of several FTC enforcement actions and potential considerations for mitigating risks arising from FTC enforcement.

Health Privacy

  • On April 26, 2024, the FTC announced that it finalized changes to its Health Breach Notification Rule (the "HBNR"). The changes clarify that the HBNR applies to online services, including mobile applications and inter-connected devices, that track health-related data or provide other health related services. Specifically, "vendors of personal health records" and related entities not covered by HIPAA are required to notify individuals, the FTC and the media of certain security breaches involving unsecured personally identifiable health data. The FTC brought its first enforcement actions

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