Originally published September 30, 2011
The United States Department of Health and Human Services has issued a voluntary model privacy notice for personal health records (PHR). The model notice is a standardized template that PHR companies can use to inform consumers about their privacy and security policies and procedures. The notice is similar to other consumer oriented "labels" that have been developed for other industries, such as the nutrition facts label for food, and the model privacy notice for the financial services industry under Gramm-Leach Bliley. However, it focuses only on some important information, and does not substitute for more comprehensive privacy policies.
Cameron Shilling is a partner at McLane, Graf, Raulerson & Middleton, and leads McLane's Privacy and Data Security Group.
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