In a new post on the Covington Digital Health blog, our colleagues discuss proposed legislation that would expand the definition of “provider of health care” under California’s Confidentiality of Medical Information Act (“CMIA”).   Under the proposed law, a provider of health care would include:

“any business that offers personal health record software or hardware to a consumer, including a mobile application or other related device that is designed to maintain personal health record system information . . . in order to make information available to an individual or to a provider of health care at the request of the individual or provider of health care, for purposes of allowing the individual to manage their information, or for the diagnosis, treatment, or management of a medical condition of the individual.”

The post walks through the proposed text and explains how the proposed legislation would impact who is required to abide by the CMIA.  The post also discusses how mobile health tracking apps have been under

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Photo of Olivia Vega Olivia Vega

Olivia Vega advises global companies on a broad spectrum of privacy, healthcare, and technology matters, helping them navigate both established and emerging laws and regulations. Her practice includes helping clients comply with state privacy laws, such as the California Consumer Privacy Act and…

Olivia Vega advises global companies on a broad spectrum of privacy, healthcare, and technology matters, helping them navigate both established and emerging laws and regulations. Her practice includes helping clients comply with state privacy laws, such as the California Consumer Privacy Act and the Washington My Health My Data Act, as well as federal frameworks like HIPAA and the privacy standards established by the Federal Trade Commission.

As part of her practice, Olivia helps clients develop privacy notices and policies, negotiate privacy terms with third-party vendors, and design governance programs for new products and services. Olivia also represents clients in enforcement actions brought by the Federal Trade Commission, particularly in areas like data privacy, artificial intelligence, and marketing practices. In addition, she plays a key role in advancing clients’ advocacy efforts during regulatory rulemaking processes on issues related to data privacy, cybersecurity, and artificial intelligence.

Olivia maintains an active pro bono practice, including assisting small and nonprofit entities with data privacy topics.

Photo of Libbie Canter Libbie Canter

Libbie Canter represents a wide variety of multinational companies on managing privacy, cyber security, and artificial intelligence risks, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with U.S. and global privacy laws.

Libbie Canter represents a wide variety of multinational companies on managing privacy, cyber security, and artificial intelligence risks, including helping clients with their most complex privacy challenges and the development of governance frameworks and processes to comply with U.S. and global privacy laws. She routinely supports clients on their efforts to launch new products and services involving emerging technologies, and she has assisted dozens of clients with their efforts to prepare for and comply with federal and state laws, including the California Consumer Privacy Act, the Colorado AI Act, and other state laws. As part of her practice, she also regularly represents clients in strategic transactions involving personal data, cybersecurity, and artificial intelligence risk and represents clients in enforcement and litigation postures.

Libbie represents clients across industries, but she also has deep expertise in advising clients in highly-regulated sectors, including financial services and digital health companies. She counsels these companies — and their technology and advertising partners — on how to address legacy regulatory issues and the cutting edge issues that have emerged with industry innovations and data collaborations.

Chambers USA 2025 ranks Libbie in Band 3 Nationwide for both Privacy & Data Security: Privacy and Privacy & Data Security: Healthcare. Chambers USA notes, Libbie is “incredibly sharp and really thorough. She can do the nitty-gritty, in-the-weeds legal work incredibly well but she also can think of a bigger-picture business context and help to think through practical solutions.”