CIPP/US Study Guide
Chapter 13: Privacy Issues in Civil Litigation and Government Investigations

Disclosures Forbidden by Law and Evidentiary Privileges

Many privacy laws forbid disclosure using opt-in or opt-out rules: HIPAA and COPPA require opt-in consent; GLBA forbids disclosure if the individual has opted out. In litigation, evidentiary privileges (attorney-client, doctor-patient, spousal, Fifth Amendment) also bar disclosure.

Privacy laws forbid disclosures using opt-in or opt-out mechanisms. HIPAA and COPPA forbid disclosure to third parties unless there is opt-in consent (or another exception). GLBA forbids disclosure to third parties if the individual has opted out. Companies not covered by GLBA may still offer an opt-out, and breaking that promise can trigger Section 5 FTC Act enforcement.

Opt-in vs opt-out trap

Watch the direction: HIPAA and COPPA are opt-in (no consent, no sharing). GLBA is opt-out (sharing is allowed unless the person says stop). Mixing these up is a classic exam error.

Evidentiary privileges, generally defined under state law, also block disclosure. The Attorney-client privilege bars compelling an attorney to testify about a client within the scope of representation (with exceptions like client consent or preventing imminent physical harm). Doctor-patient, priest-penitent, and spousal privileges work similarly, and the Fifth Amendment privilege against self-incrimination applies nationally.

Key terms - quick answers

What is “Evidentiary privilege”?
A rule (generally defined under state law) that prevents a person from being compelled to testify or produce records, such as attorney-client, doctor-patient, priest-penitent, or spousal privilege.
What is “Attorney-client privilege”?
Privilege under which an attorney cannot be compelled to testify or produce records about a client within the scope of representation, subject to exceptions like consent or preventing imminent harm.
What is “Fifth Amendment privilege”?
The constitutional privilege against self-incrimination available to a person accused of a crime in state or federal court.