Brown

In this case we address the remedies available to a patient when a debt collector, acting on behalf of a medical professional, is asserted to have illegally disclosed confidential patient medical information to various consumer reporting agencies in the course of a dispute over an alleged medical debt.

Individuals, as patients, have a substantial interest in the privacy of their medical information. (Hill v. National Collegiate Athletic Assn. (1994) 7 Cal.4th 1, 41 [ 26 Cal.Rptr.2d 834 , 865 P.2d 633 ].) As consumers, they have substantial interests as well in the privacy and accuracy of their credit information. Recognizing the importance of these interests, Congress has intervened on both fronts, enacting the Health Insurance Portability and Accountability Act of 1996 (HIPAA) (42 U.S.C. § 1320d et seq., inter alia) and the Fair Credit Reporting Act (FCRA) ( 15 U.S.C. § 1681 et seq.) to protect against the mishandling of medical information and credit information, respectively. Our Legislature has been no less diligent, enacting the Confidentiality of Medical Information Act (Confidentiality Act) (Civ. Code, § 56 et seq.) and the Consumer Credit Reporting Agencies Act…