Eve, The two laws are conceptually similar in that they give legal standing to third-party custodial agents in information governance --- great developments for UMA!. But RUFADAA and the Access Act involve different agent qualifications and oversight (for example, the Access Act positions the FTC as the regulatory body while RUFADAA custodians are unregulated). The two laws also deal with different use cases. (In other words, the Access Act doesn't encompass or even overlap the RUFADAA.) Tim On Thu, Oct 24, 2019 at 4:13 PM Eve Maler <eve@xmlgrrl.com> wrote:
Thanks Adrian! Tim, I wonder how this compares to RUFADAA. I suppose this would be a single federal law, for one. Any comments? (See "SEC. 5. DELEGATABILITY")
*Eve Maler*Cell or Signal +1 425.345.6756 | Skype: xmlgrrl | Twitter: @xmlgrrl
On Thu, Oct 24, 2019 at 2:33 PM Adrian Gropper <agropper@healthurl.com> wrote:
Here’s my analysis of the ACCESS Act
http://blog.petrieflom.law.harvard.edu/2019/10/24/access-act-points-the-way-...
Adrian
On Tue, Oct 22, 2019 at 11:02 PM Adrian Gropper <agropper@healthurl.com> wrote:
Check out https://www.warner.senate.gov/public/index.cfm/2019/10/senators-introduce-bi...
Especially Section 5: Delegation. (There's a link <https://www.scribd.com/document/431507476/ACCESS-Act-Section-by-Section-FINAL> to a nice summary at the very end of the page.) It calls for a right to specify a fiduciary agent, hopefully one that I can compile and own myself. I can imagine a law like this applying to all of our service providers above a certain size, like say 50 employees.
-- Adrian
--
Adrian Gropper MD
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