Are you using Google services to store or process protected health information (PHI)? If so, establishing a Business Associate Agreement (BAA) with Google is crucial to ensure your organization complies with HIPAA regulations. A BAA is a legally binding contract that outlines the responsibilities of both parties in protecting PHI.
Understanding the BAA
A BAA:
- Defines the scope of services provided by Google.
- Outlines the responsibilities of both parties in protecting PHI.
- Specifies the terms for handling and disclosing PHI.
- Addresses incident response procedures and breach notifications.
Obtaining a BAA with Google
To obtain a BAA with Google, you must:
- Have a paid Google Workspace account: This is a prerequisite for accessing the BAA option.
- Sign in as an administrator: The BAA process requires administrator privileges.Navigate to the Legal and Compliance section: This is typically found in the Admin console.
- Locate the HIPAA Business Associate Amendment: Look for this option under Security and Privacy Additional Terms.
- Review and accept the amendment: Carefully read the terms and conditions and answer the required questions.
Leveraging Google Cloud for HIPAA Compliance
Google offers a comprehensive HIPAA compliance guide that provides valuable insights into how Google Cloud can support your organization’s efforts to meet HIPAA requirements. This guide covers:
- Google’s approach to HIPAA compliance: Learn about Google’s commitment to data security and privacy.
- HIPAA requirements met by Google Cloud: Understand how Google Cloud services align with HIPAA regulations.
- Implementing HIPAA-compliant solutions with Google Cloud: Discover best practices and guidance for using Google Cloud to protect PHI.https://services.google.com/fh/files/misc/gsuite_cloud_identity_hipaa_implementation_guide.pdf
Google offers a HIPAA compliance guide that provides an overview of how Google Cloud can be used to support your organizations’ HIPAA compliance efforts. This guide includes information on Google’s approach to HIPAA compliance, the HIPAA requirements that Google Cloud meets, and the steps organizations can take to implement HIPAA-compliant solutions using Google Cloud.
Beyond the BAA: Ensuring HIPAA Compliance
While obtaining a BAA is essential, it’s not the sole requirement for HIPAA compliance. Your organization must also:
- Implement robust security measures: Use encryption, access controls, and regular vulnerability assessments.
- Train staff on HIPAA regulations: Ensure employees understand their responsibilities in protecting PHI.
- Conduct regular risk assessments: Identify potential vulnerabilities and address them promptly.
- Monitor and audit access logs: Track activity related to PHI to detect unauthorized access.
What is not covered under a BAA with Google
Not all of Google’s services are covered under your BAA, and it’s important that your organization is aware of what services are covered and not covered. Some of the services your may have on your website currently are not covered, and might put your organization at risk.
Here’s a list of items that your BAA doesn’t cover:
- Third-party apps: These aren’t covered by Google’s BAA. You’ll need to sign additional vendor agreements directly with these vendors. You should also disable any third-party apps that request access to your files or drives unless you have a BAA.
- Google Analytics: While Google Analytics is a powerful tool for website developers, it’s crucial to understand that its standard configuration is not HIPAA compliant. This presents a serious issue for websites handling Protected Health Information (PHI).
- Consumer Platforms: Platforms intended for personal use, such as YouTube or Blogger are not covered.
- Experimental or Pre-General Use Offerings: It’s always fun to be on the cutting edge, but in this case, you could be using technologies that aren’t covered under a BAA.
Conclusion
Establishing a BAA with Google is a vital step in ensuring HIPAA compliance for organizations that handle PHI. By following the outlined steps, leveraging Google Cloud’s capabilities, and implementing additional security measures, you can protect patient information and avoid potential legal consequences.
Don’t let HIPAA compliance keep you up at night. Let Total HIPAA handle the complexities so you can focus on what matters most. Schedule a free consultation today and ensure your organization is fully compliant.
Resources:
https://support.google.com/a/answer/3407054?hl=en
https://services.google.com/fh/files/misc/gsuite_cloud_identity_hipaa_implementation_guide.pdf
