Health data privacy laws
9 regulations worldwide that deal with health data, with every phased deadline and the official source for each.
9 regulations
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- Connecticut Data Privacy Act (CTDPA)
Connecticut
AmendedPrivacyChildrenNext: Oct 1, 2026 PA 26-64 (SB 4) amendments take effect
- European Health Data Space (EHDS)
European Union
EnactedHealth dataPrivacyNext: Mar 26, 2027 EHDS general application date
- AmendedPrivacyChildren
Next: Apr 1, 2027 Discretionary 60-day cure period ends
- GDPR
European Union
AmendedPrivacyBreach notificationNext: Apr 2, 2027 GDPR Procedural Regulation applies
- Vermont VDPOSA
Vermont
EnactedPrivacyHealth dataNext: Jan 1, 2028 Vermont Data Privacy and Online Surveillance Act takes effect
- DOJ Bulk Data Rule
United States (Federal)
In forcePrivacyData residencyEffective Apr 8, 2025
- FTC Health Breach Notification Rule
United States (Federal)
AmendedHealth dataPrivacyEffective Sep 24, 2009
- HIPAA
United States (Federal)
AmendedPrivacyHealth dataEffective Apr 14, 2003
- Washington My Health My Data Act
Washington
In forceHealth dataPrivacyEffective Mar 31, 2024
Upcoming deadlines
October 20261 deadline
PA 26-64 (SB 4) amendments take effect
Prohibits controllers and third parties from selling precise geolocation data and enacts data broker and other consumer protection provisions.
January 20271 deadline
Data broker registration required
Data brokers may not sell or license brokered personal data in Connecticut unless registered with the Department of Consumer Protection ($2,500 initial fee).
March 20271 deadline
- European Health Data Space (EHDS)European Union
EHDS general application date
The regulation applies generally from 26 Mar 2027, subject to the phased exceptions below (final article).
April 20272 deadlines
Discretionary 60-day cure period ends
The Division's discretionary notice-and-cure (at least 60 days) applies only to violations occurring on or before April 1, 2027 (Com. Law 14-4614).
January 20281 deadline
Vermont Data Privacy and Online Surveillance Act takes effect
All obligations under Act 145 apply (sec. 4).
October 20281 deadline
Data brokers must process state deletion mechanism requests
Registered data brokers must access the DCP accessible deletion mechanism at least every 45 days and process deletion requests.
March 20291 deadline
- European Health Data Space (EHDS)European Union
Primary use for first data categories; secondary use framework applies
Patient rights and EHR rules apply to patient summaries, ePrescriptions and eDispensations (Art 14(1)(a)-(c)). Chapter IV secondary-use rules (data permits, Health Data Access Bodies) apply.
June 20291 deadline
Mandatory 60-day cure period expires
The AG's duty to issue a cure notice before enforcement ends June 30, 2029 (Act 145 sec. 3).
March 20311 deadline
- European Health Data Space (EHDS)European Union
Primary use for second data categories; EHR systems in service; extra secondary-use categories
Primary-use rules extend to medical images, lab results and discharge reports (Art 14(1)(d)-(f)). Chapter III applies to EHR systems put into service under Art 26(2). Additional secondary-use categories in Art 51(1)(b),(f),(g),(m),(p) apply.
March 20351 deadline
- European Health Data Space (EHDS)European Union
Third-country participation in secondary use
Art 75(5) applies from 26 Mar 2035.
Past deadlines
August 20261 deadline
Profiling impact assessments apply
Impact assessment requirements apply to profiling activities created or generated on or after Aug 1, 2026 (Conn. Gen. Stat. 42-522 as amended).
July 20261 deadline
PA 25-113 (SB 1295) amendments take effect
Thresholds drop to 35,000 consumers or any sensitive-data processing or data sale; expanded sensitive data, minors' protections, and LLM-training disclosure in privacy notices.
April 20261 deadline
MODPA applies to personal data processing
The act applies to personal data processing activities from April 1, 2026 (Section 2 of ch. 455).
February 20261 deadline
Notice of Privacy Practices updates (Part 2 alignment)
Covered entities must update Notices of Privacy Practices under 45 CFR 164.520 for the 2024 Part 2 (substance use disorder records) changes; this NPP piece survived the Purl vacatur.
January 20261 deadline
November 20251 deadline
October 20252 deadlines
Due diligence, audit and reporting obligations apply
Subpart J (data compliance program, due diligence and audits for restricted transactions) and reporting requirements in 202.1103 and 202.1104 apply.
MODPA takes effect
Act takes effect; data protection assessments apply to processing activities on or after Oct 1, 2025.
April 20251 deadline
Prohibitions and restrictions take effect
Core prohibitions on covered data transactions and security requirements for restricted transactions apply.
March 20252 deadlines
- European Health Data Space (EHDS)European Union
EHDS enters into force
Regulation (EU) 2025/327, published 5 Mar 2025, enters into force on the twentieth day following publication.
January 20251 deadline
Universal opt-out preference signals required
Controllers must honor opt-out preference signals for targeted advertising and sale (effective Jan 1, 2025).
December 20242 deadlines
Mandatory 60-day cure period expires
After Dec 31, 2024, the AG is no longer required to offer a 60-day cure before enforcement; cure becomes discretionary.
July 20241 deadline
2024 amendments effective
Amendments clarifying health app coverage, unauthorized disclosure as breach, email notice and FTC notice timing took effect.
June 20242 deadlines
- Washington My Health My Data ActWashington
Small businesses must comply
Sections 4-9 apply to small businesses.
March 20241 deadline
- Washington My Health My Data ActWashington
Regulated entities must comply
Sections 4-9 (privacy policy, consent, consumer rights, sale authorization) apply to regulated entities.
July 20232 deadlines
- Washington My Health My Data ActWashington
Geofencing ban (Section 10) effective
Ban on geofencing around health care facilities applies to all persons.
CTDPA takes effect
Core consumer rights and controller obligations apply.
April 20231 deadline
May 20181 deadline
May 20161 deadline
February 20101 deadline
Full compliance with original Rule
Full compliance with the 2009 Health Breach Notification Rule was required.