On March 18, 2024, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) updated its guidance on the use of online tracking technology by covered entities regulated by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) OCR takes the position that a regulated entity discloses Individually Identifiable Health Information (IIHI), which is a necessary pre-condition for information to meet the definition of protected health information (PHI), it