Last year was a pivotal one for data privacy, as privacy received substantial attention from many regulators, including the Federal Trade Commission (“FTC”). Looking back at the FTC’s 2023 enforcement actions, statements and policies provides attorneys and clients with a helpful compliance roadmap of what is to come.

On April 27, 2023, the Washington State governor signed into law the My Health My Data Act or the MHMDA. In spite of the onerous and at times confusing requirements of the MHMDA, the Washington Attorney General (AG) has only published a short set of Frequently Asked Questions to help address some of this uncertainty.  Nevertheless, most of the law’s provisions take effect on March 31, 2024, meaning that, at this point, companies have a very short runway to meet their obligations and brace for the private right of action allowed for under the act.  Like so many other features of the MHMDA, data subject rights are deceptively complicated and have the potential to create significant administrative hurdles to getting it right.  As promised in our recent summary of the MHMDA (MHMDA: Time to Comply), we are examining in more detail these tricky issues in our MHMDA FAQs and have done a deep dive into data subject rights in this FAQ. 

On April 27, 2023, the Washington State governor signed into law the My Health My Data Act or the MHMDA. In spite of the onerous and at times confusing requirements of the MHMDA, the Washington Attorney General (AG) has only published a short set of Frequently Asked Questions to help address some of this uncertainty.  Nevertheless, most of the law’s provisions take effect on March 31, 2024, meaning that, at this point, companies have a very short runway to meet their obligations and brace for the private right of action allowed for under the act.   With this in mind, we have prepared this brief recap of the law and the steps companies should consider as they gear up for compliance. Our more detailed summary of the MHMDA is available in our original insight, and we will also be releasing a series of short FAQs over the coming weeks to help companies prepare.