As detailed in Part 1 of this ongoing series, Washington Governor Jay Inslee signed the state’s My Health My Data Act into law on April 27, 2023. The act is a first-of-its-kind law that creates new privacy protections relating to the collection, sharing, and selling of “consumer health data.” Most of the provisions of the act take effect on March 31, 2024. However, small businesses have an additional three months to come into compliance. Importantly, some provisions of the law may take effect earlier, including the restrictions related to geofencing, which become effective on July 23, 2023.
In this installment, we provide an overview of the consumer rights bestowed by the act and the obligations it imposes upon regulated entities and small businesses. Additionally, we identify some of the more important ambiguities and uncertainties of the act and provide key takeaways for organizations seeking to comply.
