Washington compliance for cloud-based operations
Washington compliance for cloud-based operations
Comprehensive, actionable summary of Washington compliance for cloud-based operations tailored to U.S. business owners and LLC founders.Key takeaways (short):- Washington requires breach notification for personal information (RCW chapter 19.255) and has new, state-specific privacy protections for consumer health data (My Health My Data Act / RCW 19.373) that apply broadly to entities doing business in or targeting Washington residents.
The Attorney General enforces the health-data law as a Consumer Protection Act violation. WaTech (state technology authority) publishes cloud and cybersecurity policies and provides state cloud environments configured with compliance controls (NIST, HIPAA).
Businesses must inventory data, classify consumer health data, publish required privacy notices, adopt reasonable security controls, update cloud/processor contracts, maintain incident response and breach-notification procedures, and document vendor due diligence.Practical compliance checklist (high-level):
Comprehensive, actionable summary of Washington compliance for cloud-based operations tailored to U.S. business owners and LLC founders.Key takeaways (short):- Washington requires breach notification for personal information (RCW chapter 19.255) and has new, state-specific privacy protections for consumer health data (My Health My Data Act / RCW 19.373) that apply broadly to entities doing business in or targeting Washington residents.
The Attorney General enforces the health-data law as a Consumer Protection Act violation. WaTech (state technology authority) publishes cloud and cybersecurity policies and provides state cloud environments configured with compliance controls (NIST, HIPAA).
Businesses must inventory data, classify consumer health data, publish required privacy notices, adopt reasonable security controls, update cloud/processor contracts, maintain incident response and breach-notification procedures, and document vendor due diligence.Practical compliance checklist (high-level):
Determine scope and applicability- Identify if your organization is a "regulated entity," a "processor," or otherwise covered (My Health My Data Act applies broadly; out-of-state processors serving Washington regulated entities must comply with certain sections).
Data inventory & classification- Map where Washington resident personal data (especially consumer health data) is collected, stored, processed, or hosted (including whether data is processed or stored in Washington-based cloud infrastructure).
Privacy notices & consumer rights- If subject to the My Health My Data Act, publish a consumer health data privacy policy prominently on your homepage and implement required notice/consent and rights-handling processes.
Contracts & vendor management- Update cloud and processor contracts to reflect state obligations, include security, breach-notice cooperation, subprocessor controls, and data transfer terms. Ensure processors support necessary technical controls (encryption, key management).
Security controls & standards- Adopt reasonable, risk-based controls and industry standards referenced by WaTech (NIST 800-53/800-171, HIPAA where applicable). Use encryption in transit and at rest, IAM and least-privilege, logging, vulnerability management, and backups/DR.6) Incident response & breach notification- Maintain an incident response plan with roles, detection, containment, forensics, remediation, and notification timelines that align with RCW 19.255 and AG guidance. Coordinate with cloud providers on evidence preservation and notification responsibilities.
Sector-specific obligations- Healthcare
follow HIPAA for covered entities/business associates and also comply with Washington’s My Health My Data Act for consumer health data not covered by HIPAA. Financial and education sectors must follow GLBA/COPPA in addition to state rules.
Use state tools & programs where appropriate- Washington Technology Solutions (WaTech) provides state cloud landing zones and guidance that incorporate NIST and HIPAA controls; state agencies must align with WaTech cybersecurity program policies.Why these steps are required (supporting points)
- Breach notification: Washington law requires notice to affected individuals and contains sections defining personal information and notice procedures (RCW chapter 19.255). See the statute’s chapter and section headings in the Washington RCW.- Consumer health data: Washington’s My Health My Data Act imposes specific requirements (privacy policy, consent, rights, processor obligations) and the Attorney General enforces violations as consumer protection violations; effective dates vary by business size and section.- State cyber governance: WaTech’s cloud offerings and cybersecurity program policy demonstrate the state’s preference for NIST-based controls and require agency cybersecurity programs and vendor contract alignment with state security policies.
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