Examining the Washington Attorney General’s FAQs on the My Health My Data Act

Washington’s My Health My Data Act (MHMD), signed into law at the end of April this year, left many companies scratching their heads over some of its key provisions, including effective dates and its precise scope. Most provisions of the MHMD, which is enforceable by both the state Attorney General and through a private right of action by aggrieved consumers, take effect March 31, 2024. To help companies navigate the law, the Washington Office of the Attorney General published practical guidance (FAQs) in the form of seven questions and answers that provide at least some additional clarity – however, many questions still remain. With insight from attorneys at Holland & Knight, Davis Wright Tremaine and WilmerHale, this article deciphers the FAQs and assesses outstanding questions about the MHMD’s provisions. See our two-part series on Washington’s MHMD: “Aggressive Washington Privacy Law: Right to Sue and Onerous Consent Obligations” (May 3, 2023), and “Aggressive Washington Health Privacy Law: Ten Compliance Priorities” (May 10, 2023).

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