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Diagnosing Health Care PodcastAuthor: Epstein Becker & Green, P.C.
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DOJ's Bulk Sensitive Data Transfer Rule: Key Insights for Health Care Compliance Teams
Episode 93
Thursday, 16 April, 2026
What health care and life sciences organizations need to know: "Bulk" Has a New Definition: The volume thresholds under the U.S. Department of Justice's (DOJ's) Bulk Sensitive Data (BSD) Transfer Rule are surprisingly low—sharing genomic data on just 100 people can trigger compliance requirements, catching many organizations off guard. HIPAA Compliance Is Not Enough: The BSD Transfer Rule creates an entirely new compliance layer that goes beyond existing privacy frameworks, such as the Health Insurance Portability and Accountability Act (HIPAA), applying even when data has been de-identified or anonymized. It's About Access, Not Just Transfers: Simply giving a foreign vendor, board member, or investor the ability to view sensitive data can trigger the BSD Transfer Rule—no formal data-sharing agreement is required. In this episode of Diagnosing Health Care®, Epstein Becker Green attorneys Laura DePonio, Elizabeth McEvoy, and Elena Quattrone walk health care and life sciences organizations through the DOJ's BSD Transfer Rule—from scoping and compliance to enforcement risks and exemptions. Navigate BSD Transfer Rule Compliance with Confidence: Our team has developed specific tools and advisory services to help organizations like yours understand their obligations under the BSD Transfer Rule, assess risk, and implement compliant data practices. Check out our free resource center: https://explore.ebglaw.com/resources/doj-bulk-sensitive-data-transfer-rule/ Visit our site for related resources and email contact information: https://www.ebglaw.com/dhc93. Listen to the series and subscribe for email notifications: http://diagnosinghealthcare.com. - Epstein Becker Green is a national law firm that focuses its resources on health care, life sciences, and workforce management solutions, coupled with powerful litigation strategies. This video is for informational purposes only and does not constitute legal advice. Viewing this video does not create an attorney-client relationship. DIAGNOSING HEALTH CARE® is a registered trademark of Epstein Becker & Green, P.C. © Epstein Becker & Green, P.C. All Rights Reserved. Attorney Advertising.
