What's up Wednesday - HIPAA Updates - 2

 Use of Online Tracking Technologies 

What are Tracking Technologies?

Tracking technologies are used to collect and analyze information about how users interact with regulated entities’ websites or mobile applications (“apps”). The HIPAA Rules apply when the information that regulated entities collect through tracking technologies or disclose to tracking technology vendors includes protected health information (PHI).

What do YOU need to do?

1. 

Review Tracking Technologies:

• Conduct a comprehensive inventory of all tracking technologies (like cookies, web beacons, and pixels) deployed on your websites and apps.

• Identify the specific functionalities of each tracking technology, such as analytics, advertising, or user experience enhancement.

2. 

Assess Interaction with PHI:

• Examine how these tracking technologies interact with user data, specifically focusing on the collection, storage, and transmission of protected health information (PHI).

• Determine whether the tracking technologies are used to collect directly identifiable PHI or if they have the potential to indirectly identify individuals when combined with other data.

3. 

Evaluate Purpose and Necessity:

• Evaluate the necessity of each tracking technology in the context of your operational requirements and its role in processing PHI.

• Determine if the use of each tracking technology is justified and aligns with the stated purposes of data collection and use.

4. 

Review Compliance with HIPAA:

• Assess whether the use of tracking technologies complies with HIPAA regulations, especially in terms of the minimum necessary use of PHI and ensuring appropriate safeguards.

• Check if there are any tracking technologies that are not compliant with HIPAA standards and require modification or replacement.

As always reach out to our Team if you want help or would like to discuss.

-The VanRein Team