On November 8, 2023, the Network Advertising Initiative (“NAI”) issued its best practices guidance (“Guidance”), which advocates for the use of demographic data for health advertising, rather than sensitive health information.
The Guidance comes after the FTC’s $1.5 million fine imposed on GoodRx for unauthorized disclosures of personal health information to third-party advertisers, and the recent enactment of laws such as Washington’s My Health My Data Act, which impose new restrictions on processing of health data.
