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Data privacy in healthcare is of paramount importance (and thus regulatedusing laws like HIPAA) due to the highly sensitive nature of patient data. Tothat end, healthcare organizations mention how they collect/process/store/sharethis data (i.e., data practices) via their privacy policies. Thus there is aneed to audit these policies and check compliance with respective laws. Thispaper addresses this need and presents a large-scale data-driven study to auditprivacy policies from healthcare organizations in three countries -- USA, UK,and India.  We developed a three-stage novel \textit{workflow} for our audit. First, wecollected the privacy policies of thousands of healthcare organizations inthese countries and cleaned this privacy policy data using a clustering-basedmixed-method technique. We identified data practices regarding users' privatemedical data (medical history) and site privacy (cookie, logs) in thesepolicies. Second, we adopted a summarization-based technique to uncover exactbroad data practices across countries and notice important differences.Finally, we evaluated the cross-country data practices using the lens of legalcompliance (with legal expert feedback) and grounded in the theory ofContextual Integrity (CI). Alarmingly, we identified six themes ofnon-alignment (observed in 21.8\% of data practices studied in India) pointedout by our legal experts. Furthermore, there are four \textit{potentialviolations} according to case verdicts from Indian Courts as pointed out by ourlegal experts. We conclude this paper by discussing the utility of our auditingworkflow and the implication of our findings for different stakeholders.

A Comparative Audit of Privacy Policies from Healthcare Organizations in USA, UK and India