Best Way to Maintain HIPAA Compliance in Cloud by@narendrasahoo

Best Way to Maintain HIPAA Compliance in Cloud

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Narendra Sahoo

Narendra Sahoo (PCI QSA, PCI QPA, CISSP, CISA, and CRISC) is the Founder and Director of VISTA InfoSec.

Cloud computing services offer innumerable benefits to businesses that are looking to store and access their data online. Cloud services are popular for the flexibility and convenience they offer businesses in terms of easy access and sharing critical data remotely. But what matters is the security of the data when in the cloud. Whether or not the cloud storage is secure to store, process and transfer data is a matter of major concern.

This is especially in the case of healthcare organizations like clinics, hospitals, and nursing homes that adopt cloud services for storing processing, and transferring medical information. With HIPAA regulation in place, ensuring the privacy and security of data is now an essential legal requirement.  The Health Insurance Portability and Accountability Act (HIPAA) outlines clear rules on storing and processing of medical records of patients, Protected Health Information (PHI) which is also individually identifiable health information.

So, an organization including the cloud service providers offering services of handling health records is required to ensure compliance. It is also the responsibility of healthcare organizations looking to move their patient’s health-related data to cloud storage to ensure that the Cloud Services they avail are HIPAA Compliant.

Explaining this in detail, we have shared some tips and ways how organizations looking to migrate their data to the cloud can maintain HIPAA Compliance. We have even shared some useful tips for Cloud Service Providers to ensure they offer HIPAA Compliant Cloud Storage solutions.  With the right planning and strategy in place, businesses can build a strong relationship with a Service Provider offering HIPAA Compliant Cloud Services.

HIPAA Compliant Cloud Storage

The benefits of cloud computing solutions are unmatched for businesses looking to leverage advanced technology and solutions to meet their business needs. In addition to this, Cloud Service Providers also assist businesses in terms of maintaining compliance with various industry standards and regulations including HIPAA Compliance. That said, Cloud servers are not always HIPAA compliant, but rather require additional implementation of measures to ensure HIPAA Compliant Cloud storage as per the needs of the covered entities and the regulatory requirements.


While there is no official HIPAA certification, and no government or authorizing body certifying HIPAA compliance for cloud services, it is mandatory that Covered Entities and Cloud Service Providers adhere to the HIPAA requirements. HIPAA mandates the implementation of certain requirements and levels of data privacy and security concerning Protected Health Information (PHI) and electronic Protected Health Information (ePHI). This includes implementing measures for securing and ensuring the privacy of all paper and electronically stored or transmitted PHI data.


So, when a Covered Entity stores PHI in the cloud, the cloud storage service provider also known as the Business Associate is required to implement the physical, technical, and administrative safeguards when handling PHI for ensuring compliance. Failure to implement these safeguards will result in HIPAA violations. Further, there should be a Business Associate Agreement (BAA) in place between the Covered Entities and the Cloud Service Provider that defines each of their roles and responsibilities that conform to the privacy and security standards laid out in the HIPAA rules. The agreement states that the cloud service provider shall:

  • Secure the data stored in the cloud

  • Secure the data in transition

  • Establish systems that facilitate secure data access

  • Maintain and Record logs of all activity, including all the failed and successful attempts to access

    HIPAA-compliant cloud storage requires the implementation of all the technical, physical, and administrative controls to ensure the confidentiality, integrity, and availability of ePHI. After all, it is finally the covered entity’s responsibility for developing policies and procedures covering the use of HIPAA secure cloud storage for this information.

    Tips to Maintain HIPAA Compliance

    Best Practices to Maintain HIPAA Compliance in Cloud

    When Cloud Service Providers claim to be HIPAA Compliant it means their Infrastructure is secure and maintains the privacy and security of PHI data. However, it is finally the responsibility of the Covered Entities to ensure that the Service Providers continue to meet the security requirements at all times and maintain compliance. It is their responsibility to audit and monitors the activities around the use and access of ePHI data. HIPAA requires several security implementations from Cloud Service Providers that work with Covered Entities. Discussing these security implementations in detail, below given are some tips on how to maintain and ensure HIPAA Compliance in Cloud.

    Sign a BAA

    A Business Associate Agreement is a legal document of agreement between the Covered Entities (Cloud User) and Business Associate (Cloud Service Providers) that defines roles, responsibilities, and processes to be followed by each of the entities to meet the HIPAA requirements. This helps maintain a good relationship between the two entities and ensures HIPAA Compliance.

    Access Control

    Access controls are essential for ensuring data security and privacy. It also prevents unauthorized access or alteration of data. For these reasons, all-access controls should be implemented and well configured so that only authorized individuals can access the sensitive PHI data. With appropriate access control measures in place, Cloud Users can ensure and maintain HIPAA Compliance in Cloud.

    Patch Management

    Cloud Service Providers must ensure that the cloud systems are updated to their latest version. This is to ensure that the necessary errors are rectified from time to time. In order to ensure maximum security patch management system needs to be in place to address errors, vulnerabilities, and bugs in systems. This should also include features of alerts and notifications for when a patch is needed to be applied to the cloud systems.

    Firewalls with Logging and alerting

    HIPAA clearly outlines the need to implement firewalls in systems and maintain a log for all systems and application access. HIPAA requires constant tracking or monitoring of any access to PHI data. So, organizations must enable logs on firewalls deployed in the cloud.

    This way the logs and record the way how the firewalls deployed in the cloud effectively manage the traffic. With firewalls and logs in place, the Cloud Users will get information on source and destination, IP address, port numbers, etc. which can also be used in an investigation in case of an attack. Based on the criticality, auto alerts are also required to be configured to alert personnel of any possible breach or attempt of a breach.

    2 Factor Authentication and Encryption

    The data stored in the cloud and transit must be end-to-end encrypted. HIPAA requires cloud storage to have a 2 Factor Authentication and encryption of transferred ePHI. It further requires that all the devices that store or have access to ePHI are encrypted and have systems in place for encryption keys between on-premise and cloud systems.

    File Integrity Monitoring

    Cloud Users and Cloud Service Providers must have in place measures that ensure the highest level of privacy and integrity of ePHI data. For this, they are required to set up a file integrity monitoring system that is also configured to implement a permission-based system that limits unauthorized user access. For its implementation, it requires an effective two-step authentication, secure passwords, and a secure file-sharing process that protects data from unauthorized access. Further, the file integrity monitoring systems must track and record any unauthorized access to PHI data and notify in case of any changes made to the data.

    Access Logs

    Cloud Users must implement end-to-end access logs that monitor, record, and review access to ePHI data regularly. This is to keep track of all the activities around the use and access of ePHI. Such access log information gives the organization visibility into business activities in the cloud.

    Breach Notification

    Breach Notification is one of the most important aspects of HIPAA Compliance. Both the Cloud User (Covered Entity) and Cloud Service Provider (Business Associate) are required to investigate and report their findings to the OCR when a data breach occurs. For these reasons, both Covered Entity and Business Associates must have a data breach notification in place and ensure HIPAA Compliance.

    Training for Employees

    Any personnel (internal or third-party outsourced) handling Protected Health Information (PHI) or related systems must be aware of their roles, responsibilities, and relevant security procedures. Conducting a training program is essential to ensure HIPAA controls are enforced and data stored in the Cloud are secure.

    Key Takeaways

    Collaborating with a trusted Cloud Service Provider is essential but it does not guarantee that the cloud solutions are HIPAA compliant. Cloud cannot be HIPAA compliant unless necessary measures are implemented and the systems and applications are secured.

    Both the Cloud User and Cloud Service Providers must configure security controls and monitor all the activities around ePHI data. Moreover, since it is the responsibility of Cloud User (Covered Entity) to ensure that their Cloud Service Providers are compliant (Business Associates) they need to regularly perform risk assessments. So, even if there is a signed BAA in place the Cloud Users should ensure appropriate configuration, access controls to the cloud, and logs are maintained to ensure HIPAA in Cloud.

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by Narendra Sahoo @narendrasahoo.Narendra Sahoo (PCI QSA, PCI QPA, CISSP, CISA, and CRISC) is the Founder and Director of VISTA InfoSec.
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