OCR Bulletin On Online Tracking Technologies | McDermott Skip to main content

Do Cookies Collect PHI? A Deep Dive into the OCR Bulletin on Online Tracking Technologies

Do Cookies Collect PHI? A Deep Dive into the OCR Bulletin on Online Tracking Technologies

Overview



In December 2022, the Office for Civil Rights (OCR) of the US Department of Health and Human Services issued a Bulletin that discusses the obligations of HIPAA covered entities and business associates when deploying online tracking technologies on their websites and mobile apps. The Bulletin has caused HIPAA-regulated entities to reassess when and how they collect personal information from patients and other users online.

Join a data privacy technology expert from Ankura Consulting and members of McDermott’s Healthcare and Global Privacy & Cybersecurity practices as they address the application of HIPAA to online tracking technologies and the OCR Bulletin.

Discussion topics will include:

  • An explanation of cookies, pixels and other tracking technologies
  • How to determine what information is collected through online tracking technologies
  • When information collected online is HIPAA protected health information (PHI)
  • HIPAA compliance obligations for tracking technologies processing PHI
  • Risk of compromise assessments for unauthorized disclosures to tracking technology vendors

Dig Deeper

Miami, FL / In-person / March 4-5, 2026

HPE Miami 2026

Las Vegas, NV and Virtual / Speaking Engagements / February 11 – 13, 2026

AHLA Winter Institute 2026: Advising Providers and AI in Health Care

San Francisco, CA / In-person / January 13, 2026

McDermott Forum at the 2026 J.P. Morgan Healthcare Conference

Las Vegas, NV / In-person / January 7, 2026

CES 2026 | Is Your Health Data Safe?

Get In Touch