The FTC Breach Rule did not define these guidelines as clearly for consumer-oriented health applications and services such as glucose meters and fertility trackers.
The recent policy statement clarifies and changes several interpretations of the FTC Breach Notification Rule.
The rule’s term “multiple sources” has expanded from its historical meaning of collecting information from multiple applications or services due to the policy statement. The FTC now interprets the term to include numerous mechanisms from a single consumer:
“Similarly, an app that draws information from multiple s