Odia Kagan of FoxRothschild offers some concise and sage advice:
If you are dealing with sensitive information of any kind (yes, this includes precise geolocation, ethnicity, sexual orientation, etc), but especially health information (and yes, reproductive health information too), do yourself a favor:
- Scan your website for third party trackers like Meta Pixel.
- Talk to your tech folks to understand better what is going on and whether this is going on behind a log-in.
- If you are a HIPAA covered entity, make sure your business associates do 1 and 2.
- Get a good privacy lawyer to make sure all is in order and that you are doing what needs done.
Read more at HIPAA & Health Information Technology about a lawsuit that inspires that advice.