As currently drafted, the California Consumer Privacy Act (“CCPA”) leaves many questions unresolved regarding how the law applies to data collected and used in the health care and life sciences industries, particularly in the research context. Clinical research sponsors and other industry participants have raised concerns about how the CCPA may impede care delivery and research efforts and, as a result, limit medical advancement.

Proposed CCPA amendment AB 713 would harmonize the CCPA with the de-identification standards set forth in the Health Insurance Portability and Accountability Act and its implementing regulations, expand the CCPA’s exemptions for research data, and provide other important clarifications for health care providers and their vendors, research sponsors and other organizations engaged in health care delivery or research. With this proposal, California legislators have acknowledged the need to clarify the scope of the CCPA for health care and research data, declaring the bill an “urgency statute,” meaning it would take effect immediately upon signature by the California governor.

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