Understanding S929's Effects on Small Businesses

Small Businesses

Understanding S929's Effects on Small Businesses

May be required to overhaul internal HR data handling, especially for sick leave, insurance claims, or wellness programs.

Could face costly compliance reviews, training, and audits without clear state-provided guidance.

Legal exposure if employee data is misclassified or unintentionally disclosed under the broader definition of employee information

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To: Governor Kathy Hochul
Subject: Concerns from NY Small Businesses About S929 – Health Information Privacy Act

Hi, my name is [First Name] [Last Name], and I am a part of a small business, based in New York.

[personal message]

I support the intention of S929 to strengthen protections for personal health information. However, I’m writing to share my deep concerns about the impact this bill will have on small businesses like mine.

S929 applies broad privacy requirements to routine employer functions—such as handling sick leave, insurance paperwork, and wellness benefits—without providing clarity, support, or a grace period. Even more concerning, the bill authorizes high penalties for violations, even if they result from misunderstandings or unintentional non-compliance.

For small employers, this creates an unmanageable risk. We don’t have in-house legal or compliance teams, and without explicit exemptions or state-issued guidance, we are left vulnerable.

I respectfully urge you to:

Include carve-outs or exemptions for small businesses,

Clarify the scope of “covered” HR data,

Provide implementation support and scale penalties to intent and organizational size.

Thank you for your leadership and attention to this issue. We appreciate your commitment to protecting New Yorkers’ privacy and ask that you ensure this bill doesn’t unintentionally penalize the very employers working to support our communities.

Sincerely,
[First Name] [Last Name]
[Email]