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FTC Claims Sharing User Health Data With Advertising Platforms Is a “Security Breach”

By Rebecca Engrav, Janis Kestenbaum, Cassi Carley & Perkins Coie on February 10, 2023
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For the first time, the Federal Trade Commission has brought an enforcement action under its 2009 Health Breach Notification Rule (HBNR). The case was brought against a digital health company, GoodRx Holdings, Inc., for sharing users’ health information with third-party advertising platforms without the authorization of the users whose data was being shared.

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Photo of Rebecca Engrav Rebecca Engrav

Rebecca Engrav helps companies that use data solve their highest-stakes privacy, data security, and artificial intelligence/machine learning (AI/ML) challenges before government regulators and in litigation.

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Photo of Janis Kestenbaum Janis Kestenbaum

Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security…

Janis Kestenbaum is a partner in the Privacy & Security practice and Advertising, Marketing & Promotions industry group. Janis represents companies under investigation by the Federal Trade Commission (FTC), state attorneys general, congressional committees, and foreign data protection authorities regarding privacy, data security, and consumer protection issues.

Read more about Janis KestenbaumEmail
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Photo of Cassi Carley Cassi Carley

Cassi Carley returns to Perkins Coie after working as a privacy, data, and security fellow for 2019 and 2020.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    Perkins on Privacy
  • Organization:
    Perkins Coie LLP
  • Article: View Original Source

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