Public Comments: April 2009 Proposed Rule to Implement Title II of the Genetic Information Nondiscrimination Act of 2008
The World Privacy Forum filed comments on the proposed regulations on the Genetic Information NonDiscrimination Act, or GINA. The comments request that the Equal Opportunity Employment Commission close down several potential loophole in consumer protection in the regulations. The Forum specifically asked the EEOC to consider curtailing the amount of commercially available information employers could access about employees, for example, through marketing databases. WPF also requested that those covered under GINA be required to maintain audit trails in certain circumstances, and urged that wellness programs be structured in such a way as to prevent information leakage through billing and other activities.