Practice question
A clinic lawfully processes diagnoses under the medical-treatment exception with adequate safeguards. Later it proposes disclosing named diagnoses to an advertiser for an unrelated campaign. There is no purpose-specific consent, other Section 13 exception, or other lawful authorization for that disclosure. The clinic relies solely on its original treatment basis. Which conclusion is correct?
- The treatment basis does not authorize the proposed unrelated advertising disclosure
- Every medical-treatment record becomes public after the first visit
- The original lawful collection grants unlimited downstream use
- Advertising is automatically medical treatment
- The absence of consent is irrelevant because health records are ordinary nonsensitive data
Legal references
- Republic Act No. 10173, Data Privacy Act of 2012: https://privacy.gov.ph/data-privacy-act/; Sections 3(l), 11(a) and 13.
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