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Healthcare data as a national security concern

Angela Gamalski (agamalski@honigman.com) is an Associate at Honigman LLP in Detroit, MI.

Companies operating in the healthcare industry may hold sensitive healthcare and financial data for thousands or millions of individuals. While specific healthcare data are protected by certain privacy requirements (e.g., the Health Insurance Portability and Accountability Act (HIPAA) of 1996, as amended), this broader set of sensitive individual data is also a target for national security concerns, and as such, the risk of compromise should be evaluated and appropriate security and compliance measures enacted.

As this article will explain, routine business transactions, management changes, or investments can be subject to review by the US government for national security purposes if such sensitive individual data are at stake and non-US companies or individuals are involved. Compliance and privacy professionals should understand how these risks apply to their business and work with governance and compliance stakeholders to address these risks.

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