Only days after the Federal Communications Commission (FCC) adopted a notice of proposed rulemaking to establish privacy guidelines applicable to Internet service providers (ISPs),1 the Federal Trade Commission (FTC) took two actions on the privacy front that will affect a smaller, but fast growing, industry: developers of mobile health applications. Given the pervasive use of mobile health applications, the security issues and protocols proposed by the FTC will have broad impact on the extent to which everyone’s privacy will be secured when making use of health care applications, whether for scheduling appointments, receiving the results of tests, or managing medical payments and insurance coverage.

In particular, the FTC released a new Web-based tool for developers of health-related mobile apps that, it said, was designed to help the developers understand what federal laws and regulations might apply to their apps.2 In addition, the FTC simultaneously released its own business guidance aimed at helping mobile health app developers to comply with the FTC Act by building privacy and security into their apps.3