Health Privacy

Hintze Law Global Privacy Updates

The Hintze Law team monitors global privacy and data security developments to provide timely, practical insights for clients. Below is a summary of key updates from mid-April 2026 to date.

 

US Privacy Updates

Alabama Legislature Passes Comprehensive Privacy Bill

The Alabama legislature passed a bill, which if signed by the governor, would make Alabama the twenty-second state to enact a broadly applicable comprehensive privacy law.  The law would take effect May 1, 2027, and would be enforced by the attorney general (following a mandatory forty-five-day right to cure violations).  There do not appear to be any provisions that impose materially stricter obligations on companies than those that are required under other state comprehensive privacy laws.

CPPA Public Comment Period re: Employee Data

California regulators are signaling increased oversight. On April 20, 2026, the California Privacy Protection Agency (CalPrivacy) opened a public comment period on potential updates to California Consumer Privacy Act (CCPA) requirements related to employee data. The proposed changes focus on notice, disclosure, and transparency obligations, particularly in nontraditional interfaces and employment contexts. Comments are being accepted through May 20, 2026.

In parallel, the CPPA’s newly established Audits Division is expected to begin proactive compliance reviews later in 2026. Unlike the Enforcement Division, which investigates violations, the Audits Division will evaluate business practices and identify compliance gaps, with findings potentially referred for enforcement.

Illinois BIPA Ruling

In a significant ruling interpreting the Illinois Biometric Information Privacy Act (BIPA), the U.S. Court of Appeals for the Seventh Circuit held in Clay v. Union Pacific Railroad Company (April 1, 2026) that the 2024 amendment to BIPA applies retroactively. The amendment limits damages to a “per person” basis rather than “per scan,” substantially reducing potential exposure for businesses. As a result, claims pending as of, or brought after, August 2, 2024, are subject to this reduced damages framework.

 

Maryland Legislature Passes Comprehensive Privacy Law Amendment To Restrict Data Sharing

Maryland passed HB 711, amending the Maryland Online Data Privacy Act (MODPA) to impose new restrictions on sharing personal data with government entities involved in civil immigration enforcement. The amendment limits when organizations may respond to subpoenas or cooperate with law enforcement in this context, while still allowing compliance with court-issued warrants. These changes take effect July 1, 2026.

New Jersey Health Privacy Law

New Jersey’s newly enacted Privacy Protection Act, signed March 25, 2026, introduces targeted restrictions affecting government entities and healthcare providers. The provisions for health care facilities include:

  • Prohibiting the collection of information relating to a patient's "immigration status, citizenship status, place of birth, social security number, or individual taxpayer identification number," except when necessary to ensure the safe and appropriate delivery of health care services, as applicable by law, or to provide a requested public service, benefit, or program.

·         Providing that any record relating to such information used for health care services shall not be considered a government record or disclosed except under limited statutory exceptions; and

·         Clarifying that this prohibition does not apply when the patient to whom the record or information pertains has knowingly provided written consent for disclosure.

    • "The Department of Health, in consultation with the Attorney General, shall develop and make publicly available a standardized written consent form."

These provisions take effect on April 1, 2027.

Nebraska Age-Appropriate Design Code (AAADC)

Nebraska amended its Age-Appropriate Design Code (AAADC) through legislation signed on April 17, 2026. The amendments expand the scope of regulated entities and design features, lower applicability thresholds, and introduce new requirements such as tools enabling minors to delete or unpublish accounts. The law also strengthens protections against default settings or design practices that reduce minors’ privacy protections.

Idaho Passes Social Media Child Protection Law

On April 2, 2026, Idaho’s governor signed HB 542, which applies to any social media platform that, across their corporate group (parents, subsidiaries, and affiliates), has earned at least $1 billion in advertising revenue worldwide in one or more of the preceding three years.

Covered platforms will be subject to the following requirements for Idaho users:

·         Periodic age estimation triggered by users’ cumulative use of the platform

·         Collection of date of birth for new accounts

·         Verifiable parent consent (VPC) prior to creating or maintaining an account for a child user (age 16 or younger), changing terms and conditions applicable to a child account, and changing privacy settings of a child account

·         High-privacy default settings

·         No “addictive interface features” or “profile-based paid commercial advertising” in a child account’s display/feed

·         Account deletion requirements depending on whether the request comes from a child user or their parent

This law may be enforced by a private right of action (by a child or parent), including claims of harm to mental health and emotional distress. The Idaho AG may also investigate and enforce reckless or knowing violations as per se violations of state consumer protection act. There is a three-year statute of limitations for all claims. A successful action has penalties of actual damages or $10,000, whichever is greater, and there are punitive damages available in the event of “consistent pattern[s] of reckless or knowing conduct.”

All requirements except age estimation take effect July 1, 2026. Age estimation requirements functionally* take effect January 1, 2027.

Iowa AG Files Lawsuit Against Meta for Misrepresentation of Material Harmful to Minors and Addictive Design Features

On April 8, Iowa Attorney General Bird announced a state consumer protection lawsuit against Instagram alleging youth safety and “addictive” design claims. The lawsuit alleges that Meta allow adult sexual content, alcohol, tobacco, and drug use and references, and mature/suggestive themes on Instagram despite the app’s “T for Teen” rating. The lawsuit also alleges that Instagram has addictive design features, including notifications, infinite scroll, ephemeral content, quantification and display of social interaction, and algorithmic recommendation feeds.

The lawsuit seeks a permanent injunction against Meta’s alleged misrepresentations about the content available on Instagram and “civil penalties, disgorgement, and other costs and fees.”

West Virginia and Alabama Settles Children's Safety Claims with Roblox

On April 21, 2026, the Alabama AG and the West Virginia AG both announced settlements with Roblox. (Alabama's settlement can be found here.) The agreements levee $12.5M and $11M fines respectively and impose additional requirements which include:

  • Verifying the age of all users before granting chat access,

  • Restricting adults from contacting U16 users except through verified trusted friends

  • Alerting minors upon first entering a private chat

  • Defaulting all U16 and unverified users to safe content mode

  • Allocating funds and resources to internet safety compliance and enforcement.

Multiple states also recently reached settlements with Roblox regarding children’s data and online safety practices. These agreements impose new requirements, including age verification for chat access, restrictions on adult-minor interactions, default safety settings for younger users, and enhanced compliance investments. These settlements reflect a coordinated enforcement trend focused on protecting minors online. Read about in depth in our latest blog post.

 

International Updates

China PIPL Enforcement Campaigns: Increased Scrutiny Across Key Sectors

On April 2, 2026, Cyberspace Administration of China (CAC), together with the Ministry of Industry and Information Technology (MIIT) and the Ministry of Public Security (MPS), announced a set of nationwide enforcement initiatives under the Personal Information Protection Law (PIPL). The announcement lays out the most detailed and coordinated PIPL enforcement roadmap to date.

Unlike earlier enforcement efforts that were largely complaint‑driven or ad hoc, the 2026 initiatives take a structured, sector‑by‑sector approach, with regulators spelling out exactly what they plan to inspect and where.

Key highlights include:

  • Seven targeted enforcement campaigns, covering:

    • Apps and embedded SDKs

    • Internet advertising and adtech

    • Education (with a strong focus on children’s data)

    • Transportation and mobility platforms

    • Healthcare providers

    • Financial services

    • Criminal data‑trafficking and “insider” cases

  • Explicit focus on adtech and automated decision‑making, including profiling, personalized advertising, and failure to honor opt‑out choices.

  • Increased scrutiny of SDKs, signaling that third‑party code is no longer a compliance blind spot.

  • Escalation risk: the involvement of public security authorities underscores that serious or repeated violations may move beyond administrative penalties to criminal enforcement.

European Data Protection Board 2025 Report

On April 9, 2026, the European Data Protection Board (EDPB) published a report on its work in 2025. Over the year the EDPB:

  • Published guidelines on interactions between the GDPR and other EU digital laws, including the Digital Services Act, Digital Markets Act, and the EU AI Act;

  • Published guidelines and opinions on topics such as pseudonymisation

  • Focused on the right to erasure through the 2025 Coordinated Enforcement Framework, with participation from 32 supervisory authorities and responses from 764 controllers.

 

Industry / Tech Updates

Google Analytics Changes Affecting “Sales”

Changes to Google Analytics taking effect June 15, 2026, may have significant compliance implications. Businesses will no longer be able to prevent data collected through Google Analytics from being shared with Google Ads through Analytics settings alone. Instead, service configurations will determine whether Google acts as a data processor or controller, which may affect whether data sharing constitutes a “sale” or targeted advertising under applicable laws. This change increases both regulatory risk and potential exposure under statutes such as California’s privacy laws and the California Invasion of Privacy Act (CIPA).

 

 

Hintze Law PLLC is a Chambers-ranked and Legal 500-recognized boutique law firm that provides counseling exclusively on data protection, including privacy, AI, and data security. Our attorneys and consultants support clients across technology, advertising, media, fintech, healthcare, biotech, e-commerce, and mobile sectors.

Hintze & Partners Recognized by Chambers in 2026 Global Rankings

Hintze & Partners Recognized by Chambers in 2026 Global Rankings

Hintze Law and its lawyers have once again been recognized in Chambers & Partners for expertise in Privacy and Data Security in the 2026 Chambers Global Guide. These recognitions include Hintze Law’s fifth year being ranked as an Elite Law Firm for Privacy and Data Security as well as the firm’s third year receiving recognition for Privacy and Data Security: Healthcare.

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Washington Marijuana Retailer Sued Under My Health My Data Act for Website Pixel Use

Washington Marijuana Retailer Sued Under My Health My Data Act for Website Pixel Use

by Sam Castic and Felicity Slater

A class action suit was recently filed against the companies that operate Uncle Ike's, a Seattle-area marijuana retailer. The suit filed in Washington federal court alleges common law tort claims, ECPA claims, and a claim under the My Health My Data Act (‘MHMDA’ or ‘the Act’). 

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California Prohibits AI Misrepresentations about Health Care Licenses

California Prohibits AI Misrepresentations about Health Care Licenses

By Cameron Cantrell

On October 11, 2025, California’s Governor Newsom signed AB 489, a law designed to address health advice from artificial intelligence (“AI”). It will take effect on January 1, 2026.

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California’s Healthline.com Enforcement Action Shows CCPA’s Teeth – and Sensitive Data Reach

California’s Healthline.com Enforcement Action Shows CCPA’s Teeth – and Sensitive Data Reach

By Mason Fitch and Kate Black

The California Attorney General’s Office (“OAG”) announced an enforcement action against Healthline.com on July 1 that marks a significant development in California Consumer Privacy Act (CCPA) enforcement. This action, accompanied by the largest fine under CCPA yet at $1.55 million, highlights critical areas of consideration for any company engaging in the advertising ecosystem as well as any company that processes sensitive personal information.

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Texas District Court Vacates Majority of HIPAA Reproductive Privacy Rule

Texas District Court Vacates Majority of HIPAA Reproductive Privacy Rule

by Cameron Cantrell and Felicity Slater 

On June 19, 2025, the U.S. District Court in the Northern District of Texas vacated the vast majority of the HIPAA Privacy Rule to Support Reproductive Health Care Privacy (the “HIPAA Reproductive Privacy Rule” or “Rule”). The Department of Health and Human Services (“HHS”) published the Rule in the Federal Register in April 2024 with a compliance date of December 23, 2024. The District Court’s decision to vacate the reproductive privacy aspects of the Rule has an immediate and nationwide effect.

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Hintze & Partners Recognized by Chambers in 2025 USA Rankings

Hintze & Partners Recognized by Chambers in 2025 USA Rankings

Hintze Law PLLC is delighted to announce the Chambers & Partners recognition of Susan Hintze, Mike Hintze, Sam Castic, and Mason Fitch in its USA Guide 2025. These recognitions include the firm’s sixth year being nationally ranked in Privacy and Data Security, and third year in Privacy & Data Security: Healthcare.

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Virginia Governor Signs Reproductive Health Data Restrictions into Law

Virginia Governor Signs Reproductive Health Data Restrictions into Law

by Cameron Cantrell and Felicity Slater 

On March 24, 2025, Governor Youngkin (R) of Virginia signed SB 754—which amends the Virginia Consumer Protection Act (VCPA) to restrict the collection and processing of “reproductive or sexual health information” and is enforceable through a private right of action—into law. The law will take effect July 1, 2025. 

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Fourth Circuit Publishes Landmark Ruling on 21st Century Cures Act “Information Blocking”

By Cameron Cantrell and Kate Black

On March 12, 2025, the Fourth Circuit Court of Appeals ruled that (1) the information blocking prohibition in the federal 21st Century Cures Act (“Cures Act”) was plausibly violated when an Electronic Health Record (EHR) provider blocked bot access to its systems without sufficient justification, and (2) this violation may support a Maryland state law unfair competition claim, despite the Cures Act not having its own private right of action. This decision notably appears to be the first Circuit Court decision concerning the information blocking prohibition and, for parties subject to the rule, raises the risk that information blocking may be enforceable through a de facto state privacy right of action.

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze

Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night

Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night

By Felicity Slater and Kate Black

The Maryland Online Data Privacy Act (“MODPA” or the “Act”), which takes effect October 1, 2025, establishes a set of novel requirements that will have a particular impact for companies operating in the health and wellness sectors. 

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze

Hintze & Partners Recognized by Chambers in 2025 Global Rankings

Hintze & Partners Recognized by Chambers in 2025 Global Rankings

Hintze Law and its lawyers have once again been recognized in Chambers & Partners for expertise in Privacy and Data Security in the 2025 Chambers Global Guide. These recognitions include Hintze Law’s fifth year being ranked as an Elite Law Firm for Privacy and Data Security as well as the firm’s second year receiving recognition for Privacy and Data Security: Healthcare.

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New York Legislature Passes Extraordinarily Restrictive Health Data Privacy Bill

New York Legislature Passes Extraordinarily Restrictive Health Data Privacy Bill

By Mike Hintze and Felicity Slater

Last year, we wrote about a proposed New York State law that would have significant impacts for entities that process health and wellness related data. That bill failed to pass before the 2024 legislative session ended. But today, in the early days of the 2025 session, the New York State legislature has passed Senate Bill S929 (SB S929), which is essentially unchanged from last year’s bill.  

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze

In ‘Holy Redeemer’ Settlement Agreement, OCR Continues to Prioritize Privacy Protections for Reproductive Health Information

In ‘Holy Redeemer’ Settlement Agreement, OCR Continues to Prioritize Privacy Protections for Reproductive Health Information

by Felicity Slater and Kate Black

On November 26, 2024, the Office of Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) announced a resolution agreement and corrective plan with Pennsylvania’s Holy Redeemer Hospital (Holy Redeemer). The agreement settles OCR’s claim that Holy Redeemer disclosed a patient’s protected health information (PHI)—including intimate reproductive health details—without a permissible purpose or valid authorization from the patient in violation of the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule

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A Last-Minute Push for a Reproductive Health Privacy Law in Michigan

A Last-Minute Push for a Reproductive Health Privacy Law in Michigan

By Mike Hintze and Felicity Slater 

On November 7, 2024, the Michigan legislature introduced Senate Bill 1082 / House Bill 6077, the Reproductive Data Privacy Act (the “RDPA” or the “act”). The act was introduced in the aftermath of the 2024 election cycle as Michigan Democrats brace to lose control of the House in 2025. At a hearing in the Senate Committee on Housing and Human Services, lawmakers backing the RDPA expressed a hope to pass the act before the year’s end. 

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Washington My Health My Data Act - Part 4: Effective Dates

By Mike Hintze

Yesterday the amended Senate version of the Washington My Health My Data Act was approved by the Washington State Legislature. Now that it is a near certainty the Act will become law in its current form, entities subject to the Act need to start preparing to comply. The key factor in determining deadlines for having compliance measures in place is the effective date of the Act. The Act purports to come into effect on March 31, 2024 (and for small businesses, three months later on June 30, 2024). However, contrary to stated legislative intent, and due to what one can only conclude is, at least in part, a drafting error, some of the key substantive provisions of the Act may come into effect much sooner than expected - as soon as July 2023. 

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze

Washington My Health My Data Act - Part 3: The Scope of Entities and Consumers Captured by the Act

By Mike Hintze

The Washington My Health My Data Act applies to “regulated entities” that collect or process “consumer health information” from “consumers.” Part two of this series addressed the definition of “consumer health data” and how that definition results in a scope of applicability that is far beyond what we might typically think of as sensitive health data. But the other two above-quoted defined terms – “regulated entity” and “consumer” also result in a very broad (and in some ways surprising) scope and impact. 

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze

Washington My Health My Data Act - Part 2: The Scope of “Consumer Health Data”

By Mike Hintze

The substantive requirements of the Washington My Health My Data Act apply to collection, use, and disclosure of “consumer health data.” While there are a few important exclusions, the stunning breath of that term's definition, means that it will be difficult to safely conclude that any category of personal data is out of scope of the Act. As a result, it is inaccurate to refer to the Washington My Health My Data Act as a “health data privacy law.” On the contrary, it is, in effect, a generally-applicable privacy law. 

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze

The Washington My Health My Data Act - Part 1: An Overview

By Mike Hintze

The Washington My Health My Data Act will become the most consequential privacy legislation enacted in 2023. The sweeping scope and extreme substantive obligations, combined with vague terms and with a full private right of action, make this Act extraordinarily challenging and risky for entities seeking to comply with its requirements.

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Don’t Sleep on Maryland: The Maryland Online Data Privacy Act Will Keep Health and Wellness Companies Up at Night — Hintze