Last May, around the time many schools let out for the summer, the Office for Civil Rights (“OCR”) published guidance entitled “Direct Liability of Business Associates” (the “Guidance”), which focuses, not surprisingly, on OCR’s ability to take enforcement action directly against HIPAA business associates. I meant to write about this guidance before Memorial
Medical Records
Dutch Hospital Fined Under GDPR for Medical Records Access Lapses

The Dutch Data Protection Authority has levied a fine of 460,000 euros on Haga Hospital for insufficient security following an investigation revealing that dozens of hospital staff had unnecessarily checked the medical records of a well-known Dutch person.
In addition, if the hospital has not improved security before October 2, 2019, it must pay 100,000…
Top 5 Common HIPAA Mistakes to Avoid in 2018
Heading into its 22nd year, HIPAA continues to be misunderstood and misapplied by many, including health care industry professionals who strive for (or at least claim the mantle of) HIPAA compliance. Here is my “top 5” list of the most frequent, and most frustrating, HIPAA misperceptions seen during 2017:
- “If I’m using or disclosing
…
HIPAA-Type Protections Are Not Just For Humans – When It Comes To Medical Records, Animals Have Privacy Rights, Too (Part 1)
Co-authored by Nancy Halpern, DVM, Esq.; also posted on Animal Law Update
HIPAA does not protect animals’ health information – it applies to the protected health information (or PHI) of an “individual”, defined as “the person who is the subject of” the PHI. However, state laws governing the confidentiality of health information also come…
Massachusetts Hospital Rescues “Orphan” Medical Records
The abandoned records of an Acton, Massachusetts physician who abruptly closed his office have been saved from the shredder by the last-minute intervention of a local hospital, highlighting a potential gap in state law that may leave patients unprotected in similar situations.
According to the Boston Globe, Dr. Ronald Moody’s landlord evicted him from…