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Chronicles

The story behind the story

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Washington becomes the first US state to adopt sweeping safeguards for consumer health data, including location records that could reveal abortion clinic visits

Andrea Vittorio / Bloomberg Law :

Bloomberg Law Andrea Vittorio

Context & Ripple Effects

Washington’s measure follows a growing state-by-state privacy patchwork: Virginia had already enacted a broad consumer privacy law, while California later limited out-of-state abortion-related demands for Californians’ information. Virginia’s comprehensive privacy law and California’s abortion-data disclosure restriction show states addressing different parts of the same data-governance gap.

The abortion-clinic angle is especially salient because a location-data company reported buyer interest in device data associated with clinic visits after the draft Roe decision. Reported demand for clinic-visit location data turned a general privacy concern into a concrete health-data risk.

First-order effects

  • Businesses handling Washington consumers’ health-related information and location records face new safeguards around data that could expose sensitive care decisions.
  • Location-data and data-broker practices involving visits to abortion clinics become a more immediate compliance and reputational concern in Washington.

Second-order effects

  • Companies operating across states must account for another distinct privacy regime, reinforcing the multistate compliance burden already anticipated as state privacy bills proliferated.
  • Buyers and sellers of location-derived audience data may face reduced willingness to transact in especially sensitive health-adjacent segments, even where the underlying data is not framed as medical records.

Third-order effects

  • If other states adopt similarly targeted rules, U.S. privacy regulation could increasingly govern data by its practical sensitivity—such as what location can reveal—rather than only by traditional medical-data categories.
  • The measure points toward a more fragmented state privacy market, in which health, reproductive-care, and location data become early testing grounds for stricter limits on data collection and disclosure.

The trend: State privacy policy is moving from broad consumer rights toward targeted controls on data that can reveal sensitive real-world behavior.

Discussion

  • @slaterfe Felicity Slater on x
    1⃣🗺️Marking the passage of the Washington ‘My Health, My Data’ Act today with a ceremonial @futureofprivacy expansion of the patchwork, and some new resources: https://twitter.com/...
  • @jakelaperruque @jakelaperruque on x
    Couple notes: -Limiting repro data collection is a big measure -Doesn't follow CA's AB 1242 in terms of blocking out of state data demands -Rules like in-state geofence limit will become increasingly important as cross-state bans like Idaho's get passed https://twitter.com/...
  • @govinslee Governor Jay Inslee on x
    This time last year the Supreme Court's calamitous Dobbs decision was leaked, and I stood with some of the other elected leaders here to put the anti-choice cabal on notice: Washington state will not go back. #waleg https://medium.com/...