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SettlementMedium Risk

NY AG Fines NewYork-Presbyterian $300K for HIPAA Website Tracking Violations

NewYork-Presbyterian HospitalDecember 27, 2023New York Attorney General

Penalty Amount

$300,000

Consumers Affected

54,000

Summary

NewYork-Presbyterian Hospital used third-party tracking tools on its website that collected and shared patients' health information with tech companies without adequate safeguards, violating HIPAA. The hospital agreed to pay $300,000 and implement enhanced privacy policies, data deletion, and regular audits.

Remedy

NYP must pay $300,000, adopt policies to prevent disclosure of protected health information through tracking tools, conduct regular audits of third-party tools, review contracts and privacy policies, and instruct third parties to delete any protected health information received.

Monetary PenaltyData DeletionCompliance ProgramAudit Requirement

Contract Impact

In-house legal teams should review all vendor and customer agreements where the entity's website or digital platforms are involved, particularly those with third-party technology, marketing, or analytics providers. Specific clauses to scrutinize include data sharing provisions, consent and authorization mechanisms (especially for PHI), breach notification requirements, data retention and deletion obligations, audit rights, and representations regarding HIPAA compliance. Changes may be needed to mandate Business Associate Agreements (BAAs) for all vendors handling PHI, implement stricter pre-deployment vetting and approval processes for tracking/analytics tools, require explicit and granular user consent for data collection, and incorporate robust data deletion and security safeguards aligned with HIPAA's minimum necessary standard.

Contract Search Terms

third-party tracking toolswebsite analyticsprotected health information (PHI)business associate agreement (BAA)data sharing agreementconsent mechanismsdata retention schedulebreach notification clausevendor management policiesprivacy policy updates

Laws Cited

HIPAA

Violation Types

Entity Details

Entity

NewYork-Presbyterian Hospital

Also known as: NewYork-Presbyterian

Industry

Healthcare

Official Sources

Source Evidence

Entity Name
"The NewYork-Presbyterian Hospital"
Fine Amount
"$300,000"
Laws Cited
"Health Insurance Portability and Accountability Act (HIPAA)"
Violation Types
"for disclosing the health information of individuals who visited their website"
Consumers Affected
"affected over 54,000 people"

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