Comment: The Health Insurance Portability and Accountability Act (HIPAA) has become one of the most widely recognized compliance frameworks in the healthcare industry. HIPAA was enacted in 1996 to protect the privacy and security of protected health information (PHI), which includes sensitive data such as names, addresses, Social Security numbers, health records, and biometric information. As part of HIPAA compliance, organizations that collect or store this data must follow strict guidelines to ensure it is stored, used, and shared properly.
The importance of HIPAA compliance has increased in recent years, as healthcare organizations have become prime targets for cyberattacks. High-profile incidents at organizations such as Kaiser Permanente, HealthEquity, and Concentra Health Services have exposed millions of patient data, demonstrating the high stakes of maintaining proper security. In the event of a breach, failure to demonstrate HIPAA compliance can result in hefty fines, reputational damage, and potentially significant financial losses. In some cases, companies may choose to pay ransoms to keep breaches secret, underscoring the devastating impact that noncompliance can have.
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Since PHI data is stored both on-premises and in the cloud, it is important to understand how HIPAA compliance differs in these environments. One important difference between the two is accountability and control.
Understanding the Shared Responsibility Model
When discussing HIPAA compliance in the cloud, it is important to recognize the shared responsibility model. In an on-premises environment, an organization has complete control over its infrastructure, from physical security to network configuration and data protection. However, in a cloud environment, this responsibility is shared between the cloud provider and the user.
Cloud service providers, such as AWS, Azure, or Google Cloud, are responsible for securing their infrastructure, including physical hardware, underlying networks, and core services. Users, on the other hand, are responsible for securing their applications, data, and any configurations related to how their services run in the cloud.
This model introduces complexity when it comes to PHI data. Organizations must secure their cloud configurations, identities, and data while ensuring that cloud and software providers are meeting their compliance obligations. As the cloud introduces new layers of abstraction, it is easy to overlook critical security aspects, potentially creating gaps that can put PHI data at risk if not managed properly.
How to Keep Your PHI Data Secure in the Cloud
To keep PHI data secure in the cloud, organizations must actively monitor, detect, and fix potential vulnerabilities. Cloud environments are dynamic, requiring security configurations to adapt as applications evolve. A major challenge in these environments is maintaining control over third-party services, which can introduce additional risks.
Many cloud-based organizations rely heavily on third-party vendors, but their security posture directly impacts an organization’s HIPAA compliance status. When working with third parties, it is critical to ensure that they follow HIPAA compliance standards, as any vulnerabilities on their part could compromise the overall security of your PHI data.
The challenge doesn’t stop there. In the cloud, organizations need to continuously audit and monitor their environments to ensure they are compliant with HIPAA regulations. This includes leveraging cloud-native tools like AWS CloudTrail, Azure Monitor, and Google Cloud Security Command Center to track activity and ensure that the team is properly securing the cloud infrastructure.
Here are three important elements of a strategy that will help organizations make their cloud data HIPAA compliant:
In addition to securing PHI data, organizations must also put in place the right auditing and monitoring processes. Logging tools allow organizations to track and record every action taken within their cloud environments. This helps identify and address security configuration errors or unauthorized access in real-time, ensuring that the team can address any compliance gaps immediately.
Make cloud-native tools the foundation of your company’s compliance monitoring strategy. Starting with these tools allows organizations to leverage services that are already optimized for the specific cloud platform they are using. From there, the team can add additional third-party security tools to provide enhanced monitoring and auditing capabilities.
Any organization that handles protected health information must struggle to comply with HIPAA, and the cloud introduces new complexities to maintaining that compliance. By understanding the shared responsibility model, implementing strong security practices such as encryption and access control, and continuously monitoring for vulnerabilities, organizations can ensure that their cloud environments remain compliant. Proactively securing protected health data and working closely with third-party vendors can protect sensitive information, build customer trust, and help avoid costly breaches and regulatory penalties.
Shira Shamban, Co-Founder and CEO of Solvo
SC Media Perspectives columns are written by SC Media’s trusted community of cybersecurity subject matter experts. Each contribution is intended to provide a unique voice on important cybersecurity topics. Content strives to be of the highest quality, objective, and non-commercial.
