Penalty Amount
$2,500,000
Consumers Affected
84,000
Monument, Inc., an alcohol addiction treatment firm, shared consumers' health data with third-party advertising platforms like Meta and Google without consent, despite promising confidentiality. The FTC settled with a consent order that bans Monument from disclosing health data for advertising, requires affirmative consent for other sharing, imposes a $2.5 million suspended fine, and mandates data deletion, consumer notification, and a privacy program.
Monument is banned from disclosing health information for advertising and must obtain affirmative consent before sharing health information for any other purpose. The company must pay a $2.5 million civil penalty (suspended), delete user data shared with third parties, notify affected consumers, and implement a comprehensive privacy program with data retention limits.
In-house legal teams should review all agreements involving consumer health data, particularly vendor contracts with advertising platforms (e.g., Meta, Google), customer Terms of Service/Privacy Policies, and Data Processing Agreements (DPAs). Specific clauses to scrutinize include: (1) data sharing and licensing provisions to ensure they explicitly prohibit using sensitive health information for advertising/targeting; (2) consent mechanisms to verify they require clear, affirmative, and separate consent for any health data sharing beyond core service delivery; (3) confidentiality and data security clauses to align with promised protections; and (4) audit and compliance reporting requirements. Changes needed will likely involve adding explicit bans on using health data for ads, implementing granular consent flows, strengthening data deletion protocols, and mandating regular privacy program assessments and reporting.
Entity
Monument, Inc.
Also known as: Monument
Industry
HealthcareOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2024/04/alcohol-addiction-treatment-firm-will-be-banned-disclosing-health-data-advertising-settle-ftc
MonumentOrderFiled
https://www.ftc.gov/system/files/ftc_gov/pdf/MonumentOrderFiled.pdf
MonumentComplaintFiled
https://www.ftc.gov/system/files/ftc_gov/pdf/MonumentComplaintFiled.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"New York-based Monument, Inc."
"imposes a $2.5 million civil penalty"
"FTC Act’s prohibition against unfair and deceptive practices"
"Opioid Addiction Recovery Fraud Prevention Act of 2018 (OARFPA)"
"FTC says Monument shared consumers’ health data with third-party advertising platforms without consent"
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