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Michael Egan

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In Cloud Computing

OCR Issues Guidance on Cloud Computing and the FTC Act

by 4 Mins Read

In October 2016, federal authorities released two important guidance materials for businesses handling health information to consider. The Department of Health and Human Services, Office for Civil Rights (“OCR”) released guidance on (1) the application of HIPAA to cloud computing, and (2) the importance of the Federal Trade Commission Act (“FTC Act”) in the context of sharing protected health information (“PHI”). These materials are important because OCR is responsible for enforcing the Health Insurance Portability…

In Privacy Shield

Privacy Shield’s First Month – A Snapshot

by 3 Mins Read

After much negotiation between the U.S. and European authorities, the Department of Commerce (DOC) began accepting applications to the EU-U.S. Privacy Shield Framework on August 1, 2016. Although there was considerable speculation about whether U.S. companies would participate in the program due to the possibility of legal challenges in Europe and the more stringent requirements of Privacy Shield over Safe Harbor, more than 75 companies have already completed the self-certification process, and many more have…