The Federal Trade Commission (FTC) has enforced its Health Breach Notification Rule (the “HBNR”) for the first time since it was enacted in 2009. On February 1, the FTC announced a first-of-its-kind proposed order (the “Order”) with digital health platform GoodRx Holdings Inc. (“GoodRx”), a telehealth and drug discount provider. The FTC alleged that GoodRx shared users’ information with third-party advertising companies and advertising platforms contrary to its privacy promises, notably scrutinizing GoodRx’s ad targeting and use of third-party tracking technologies.
Read the full client alert.