The World Privacy Forum submitted comments to the U.S. Occupational Safety and Health Administration regarding updates to the definition of "employee medical record" to fit the agency's new standards for employee COVID-19 vaccine information. Following its own analysis, WPF opined the current definition for medical health records "is a decidedly pre-pandemic definition" and would not necessarily cover all forms of vaccine information, specifically information that "may not have been created by just health care providers, and where individuals and other non-HIPAA covered entities may hold the records."
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