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SCENARIO Please use the following to answer the next question; Miraculous Healthcare is a large medical practice with multiple locations in California and Nevada. Miraculous normally treats patients in person, but has recently decided to start offering teleheaith appointments, where patients can have virtual appointments with on-site doctors via a phone app For this new initiative. Miraculous is considering a product built by MedApps, a company that makes quality teleheaith apps for healthcare practices and licenses them to be used with the practices' branding. MedApps provides technical support for the app. which it hosts in the cloud MedApps also offers an optional benchmarking service for providers who wish to compare their practice to others using the service Riya is the Privacy Officer at Miraculous, responsible for the practice's compliance with HIPAA and other applicable laws, and she works with the Miraculous procurement team to get vendor agreements in place. She occasionally assists procurement in vetting vendors and inquiring about their own compliance practices. as well as negotiating the terms of vendor agreements Riya is currently reviewing the suitability of the MedApps app from a privacy perspective. Riya has also been asked by the Miraculous Healthcare business operations team to review the MedApps' optional benchmarking service. Of particular concern is the requirement that Miraculous Healthcare upload information about the appointments to a portal hosted by MedApps What is the most practical action Riya can take to minimize the privacy risks of using an app for telehealth appointments?



SCENARIO Please use the following to answer the next QUESTION: You are the chief privacy officer at HealthCo, a major hospital in a large U.S. city in state A. HealthCo is a HIPAA-covered entity that provides healthcare services to more than 100,000 patients. A third-party cloud computing service provider, CloudHealth, stores and manages the electronic protected health information (ePHI) of these individuals on behalf of HealthCo. CloudHealth stores the data in state B. As part of HealthCo's business associate agreement (BAA) with CloudHealth, HealthCo requires CloudHealth to implement security measures, including industry standard encryption practices, to adequately protect the data. However, HealthCo did not perform due diligence on CloudHealth before entering the contract, and has not conducted audits of CloudHealth's security measures. A CloudHealth employee has recently become the victim of a phishing attack. When the employee unintentionally clicked on a link from a suspicious email, the PHI of more than 10,000 HealthCo patients was compromised. It has since been published online. The HealthCo cybersecurity team quickly identifies the perpetrator as a known hacker who has launched similar attacks on other hospitals -- ones that exposed the PHI of public figures including celebrities and politicians. During the course of its investigation, HealthCo discovers that CloudHealth has not encrypted the PHI in accordance with the terms of its contract. In addition, CloudHealth has not provided privacy or security training to its employees. Law enforcement has requested that HealthCo provide its investigative report of the breach and a copy of the PHI of the individuals affected. A patient affected by the breach then sues HealthCo, claiming that the company did not adequately protect the individual's ePHI, and that he has suffered substantial harm as a result of the exposed data. The patient's attorney has submitted a discovery request for the ePHI exposed in the breach. What is the most significant reason that the U.S. Department of Health and Human Services (HHS) might impose a penalty on HealthCo?




Question 8 - CIPP-US discussion

Report
Export

Which was NOT one of the five priority areas listed by the Federal Trade Commission in its 2012 report, ''Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers''?

A.

International data transfers

Answers
A.

International data transfers

B.

Large platform providers

Answers
B.

Large platform providers

C.

Promoting enforceable self-regulatory codes

Answers
C.

Promoting enforceable self-regulatory codes

D.

Do Not Track

Answers
D.

Do Not Track

Suggested answer: D

Explanation:

The Federal Trade Commission (FTC) issued its 2012 report, ''Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers''1, which outlined a framework for privacy protection based on three main principles: privacy by design, simplified consumer choice, and greater transparency. The report also identified five priority areas for the FTC's privacy enforcement and policy efforts, which were:

Data brokers

Large platform providers

Mobile

Promoting enforceable self-regulatory codes

International data transfers

Do Not Track was not one of the five priority areas, but rather a specific mechanism for implementing the principle of simplified consumer choice.The report endorsed the development of a Do Not Track system that would allow consumers to opt out of online behavioral advertising across websites and platforms1.The report also noted the progress made by various stakeholders, such as the World Wide Web Consortium (W3C), the Digital Advertising Alliance (DAA), and browser companies, in advancing the Do Not Track initiative1.Reference:1: Federal Trade Commission, Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers (March 2012), available at1.

asked 22/11/2024
George Sanchez
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