Gramm-Leach-Bliley legislation and HIPAA
HIPAA Weekly Advisor, September 10, 2001
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Q: Can the privacy notice required by the Gramm-Leach-Bliley legislation be combined with the HIPAA privacy notice?
A: They will have to be separate, but you could probably include them in the same package.
There are some differences. The Gramm-Leach-Bliley Act (GLB) has some more stringent requirements in terms of the opting out provisions, where HIPAA's a bit weaker. There are certainly similarities, but they're not exactly identical. But if you've gone through the GLB notice, that will help you. You'll be better positioned to develop the HIPAA one, but not combine them.
It is acceptable to send these notices along with other mailings you're doing.
Answered by Kate Borten, CISSP, president of the Marblehead Group in Marblehead, MA, and William Miaoulis, CISA, Managing Associate at SAIC - Health Solutions Group. You can e-mail them at kborten@marbleheadgroup.com and WILLIAM.M.MIAOULIS@saic.com
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