Carolyn Metnick Carolyn Metnick

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Carolyn V. Metnick represents a range of healthcare industry clients, including hospitals and health systems, physician organizations and digital health companies. She advises on healthcare regulatory and transactional matters with a focus on health information privacy and security. Carolyn advises clients on a range of privacy and security laws, including HIPAA and the California Consumer Privacy Act (CCPA). She also counsels businesses in data breach investigations and compliance with federal and state breach notification laws. Carolyn is a Certified Information Privacy Professional/United States (CIPP/US) and a Certified Information Privacy Professional/Europe (CIPP/E). Read Carolyn V. Metnick's full bio.

FTC Issues Policy Statement Expanding Interpretation of Health Breach Notification Rule’s Scope


By , , and on Oct 13, 2021
Posted In Digital Health, Employee Benefits, Health and Welfare Plans, Privacy and Data Security

On September 15, 2021, the Federal Trade Commission (FTC) voted 3–2 along party lines (with Republican commissioners dissenting) to issue a policy statement announcing an expansive interpretation of the FTC’s Health Breach Notification Rule, 16 CFR Part 318 (the Rule). According to the policy statement, the Rule applies to health apps and connected devices that...

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