CDT has filed these comments in advance of the FTC's 3rd "Exploring Privacy" Roundtables.
CDT is a non-profit public interest organization founded in 1994 and dedicated to keeping the Internet open, innovative and free. With offices in Washington, DC and San Francisco, CDT works with all interested stakeholders to develop and advance public policies, corporate practices and technology designs that enhance free expression, privacy, and democratic participation. Through research, dialogue, and advocacy, CDTʼs Health Privacy Project is promoting pragmatic, effective actions to better protect the privacy and security of electronic health information and build consumer trust in a wired health care system, so that the benefits of health information technology can be realized. CDTʼs work on consumer privacy on the Internet focuses on protecting the privacy of consumerʼs health information on-line, as consumers increasingly use the Internet to access and share health information on-line. This FTC roundtable touches on CDTʼs work in these areas.
Thank you for the opportunity to submit these comments to the Third Roundtable on Privacy. Those expressed here focus on protections for health information as part of electronic medical records kept by traditional participants in the health care system (such as physicians and other care providers, hospitals, and health plans), and personal health records, which are commonly offered by Internet companies and allow consumers to store and share copies of their health information with their health care providers and others as they see fit. We also briefly address FTCʼs specific question for this Roundtable on different standards for minors. CDT also is separately submitting comments for this Roundtable on identity management and submitted comments for previous Roundtables on on-line privacy with respect to sensitive personal information, including health.