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The Red Flag Rule for Healthcare
Naomi Lefkovitz
Attorney, Division of Privacy and Identity Protection
Federal Trade Commission
Naomi Lefkovitz is an attorney with the Division of Privacy and Identity Protection at the Federal Trade Commission. Her responsibilities focus primarily on business and consumer education, legislative activity, and rulemakings. She specializes in identity theft issues, in particular, the areas of identity management, authentication, and fraud prevention. She has drafted a number of rulemakings related to identity theft including representing the FTC in the inter-agency group that drafted the Red Flags Rule.
Ms. Lefkovitz joined the FTC in 2001. For the five years prior to working at the FTC, she was Assistant General Counsel at CDnow, Inc., an online music retailer. At CDnow, Inc., she was responsible for negotiating and drafting contracts, managing intellectual property matters, lobbying and trade association participation as well as other corporate matters.
Ms. Lefkovitz holds a B.A. with honors in French Literature from Bryn Mawr College and a J.D. with honors from Temple University School of Law.
Pam Dixon
Executive Director
World Privacy Forum
Pam Dixon is a researcher, author, and the executive director of the World Privacy Forum. She founded the World Privacy Forum -- a public interest research group focused on conducting in-depth privacy research and consumer education -- in November 2003. There, she publishes widely cited privacy studies and research. She is on the board of HITSP, and serves as co-chair of the California Privacy and Security Advisory Board (CalPSAB.)
In addition to publishing seven books, Dixon has authored key privacy studies, including the groundbreaking Medical Identity Theft report (2006), the first major research to be published on the topic and widely considered the definitive report on the topic. In fall 2008, Dixon co-hosted an international privacy and security conference in Tokyo, Japan with 17 universities; it was the first major privacy conference of its kind to be held in that region. Dixon has testified on consumer interests in health care privacy and on other facets of privacy before numerous bodies, from Congressional subcommittees such as NCVHS to the Secretary’s Advisory Committee on Genomics, Health, and Society (SACGHS) to the California Senate.
Bob Gellman
Privacy and Information Policy Consultant
Robert Gellman is a privacy and information policy consultant in Washington, D.C. He advises large and small companies, for-profit and non-profit organizations, trade associations, government agencies, foreign governments, and advocacy organizations how to develop, analyze, implement, and maintain policies for personal privacy and fair information practices. Specialty areas include privacy policy for health (including HIPAA), the Internet, and the homeless; freedom of information, and other information policy areas. A graduate of the Yale Law School, Gellman has worked on information policy issues for more than 30 years. He spent 17 years on the staff of a Subcommittee in the House of Representatives responsible for privacy, freedom of information, health record confidentiality, and other information policy matters. He served as a member of the Department of Health and Human Service's National Committee on Vital and Health Statistics (1996-2000), a federal advisory committee with responsibilities for health information infrastructure matters, and he chaired the Privacy and Confidentiality Subcommittee for two years. He is the author of numerous columns, conference papers, congressional reports, and scholarly articles on privacy and other information policy issues. Many are available at www.bobgellman.com. A recent publication is Notes and Observations on Selected Parts of Title XIII, Subtitle D, Privacy, American Recovery and Reinvestment Act Of 2009, available at http://bobgellman.com/rg-docs/Stimulus-Privacy-HIPAA-Analysis.pdf. Recent publications for the World Privacy Forum include: Privacy in the Clouds: Risks to Privacy and Confidentiality from Cloud Computing, available at http://www.worldprivacyforum.org/cloudprivacy.html; Personal Health Records: Why Many PHRs Threaten Privacy (together with a consumer advisory) available at http://www.worldprivacyforum.org/personal_health_records.html; Patient’s Guide to HIPAA, available at http://www.worldprivacyforum.org/hipaa/index.html; Red Flag and Address Discrepancy Requirements: Suggestions for Health Care Providers, available at http://www.worldprivacyforum.org/pdf/WPF_RedFlagReport_09242008fs.pdf; and FAQs for Victims of Medical Identity Theft, available at http://www.worldprivacyforum.org/FAQ_medicalrecordprivacy.html.
Jennifer Karron
Partner
Foley & Lardner LLP
Jennifer G. Karron is a partner in Foley's Finance & Financial Institutions and Privacy, Security & Information Management Practices. She specializes in consumer credit, privacy and electronic payment transactions. Ms. Karron routinely counsels both Fortune 500 companies and small financial services providers regarding the Fair Credit Billing Act, the Truth-in-Lending Act, the Equal Credit Opportunity Act, the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, the Gramm-Leach-Bliley Act, federal and state Do Not Call Rules, and state consumer credit, privacy and debt collection laws. She has drafted numerous compliance manuals and disclosures, including privacy and Truth-in-Lending disclosures, for financial institutions and retail businesses.
Ms. Karron also assists clients in developing online payments systems, as well as payment products such as stored value cards, payroll cards and electronic payment instruments. She provides advice regarding compliance with federal and state electronic fund transfer laws, the National Automated Clearing House Rules, electronic signature laws and state money transmission statutes. Ms. Karron has extensive experience negotiating co-branded and private label credit card agreements and credit card processing agreements.
Ms. Karron received her B.A. in Honors English from Georgetown University. She graduated summa cum laude from Marquette University Law School in 1993, where she received the Law Alumni Award for the highest cumulative grade point average. She is the author of "Get the Facts on FACTA: What You Should Know About the Amendments to the Fair Credit Reporting Act"; "The ‘Do Not Call' Rules: Is Your Telemarketing Headed for a Hang-up?"; and "The Effect of Gramm-Leach-Bliley on State Affiliated Business Laws: Will Federal Preemption Bring the State Walls Down?" published by Real Estate Services Providers Council, Inc.
Ms. Karron serves on the board of directors of Literacy Services of Wisconsin, Inc.
The Red Flag Rule for Healthcare
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