1. 25. See White House, “Administration Discussion Draft: Consumer Privacy Bill of Rights Act of 2015,” February 27, 2015, available at (last visited January 20, 2020). The criteria resemble the Common Rule’s criteria for waiving consent. See infra Part III.
2. The historical foundations of the research-practice distinction in bioethics
3. 24. Consumer Privacy Protection Act of 2015, S. 1158, 114th Cong.
4. 91. 45 C.F.R. §46.104(d)(8)(iv).
5. 42. Id., at 7-8.