HIPAA Compliance

Our comprehensive HIPAA compliance dashboard

HIPAA safeguards enabled

HIPAA compliance is woven into Harper’s DNA. Explore the safeguards, procedures, and evidence that prove we protect electronic protected health information at every layer—from governance to infrastructure and day-to-day operations.

Safeguards documented
100

Controls across governance, privacy, security, and resilience.

Required controls
21

Mandatory HIPAA safeguards implemented and monitored.

Addressable controls
14

Tailored safeguards with documented rationale and outcomes.

0

Scope & Governance

Foundational

We anchor our privacy and security program with clear governance, accountable owners, and documented processes that stay aligned with the HIPAA Privacy, Security, and Breach Notification Rules.

  • Role classification & ePHI data flows

    We document where Harper serves as a Business Associate versus a Covered Entity and maintain detailed architecture diagrams that trace every stream of ePHI across our platform.

  • Dedicated Privacy and Security Officers

    Named leaders hold written charters that outline their responsibilities for day-to-day operations, policy oversight, and board reporting.

  • Comprehensive HIPAA policy library

    Our policy set spans Privacy, Security, Breach Notification, sanctions, vendor governance, BYOD, telehealth, and remote work with formal version control and annual review cycles.

  • System inventory & data mapping

    We maintain a living catalog of applications, services, vendors, and data stores, each tagged with the ePHI elements it touches and supporting data flow diagrams.

  • Complaint handling & non-retaliation

    Employees and customers can raise privacy or security concerns through multiple channels; every submission is tracked to closure with a strict non-retaliation stance.

  • Security metrics & monitoring cadence

    We run a quarterly scorecard that covers incident trends, training completion, vendor reviews, backup verification, and risk remediation progress.

  • Annual compliance calendar

    Recurring tasks such as risk analysis, tabletop exercises, policy attestations, and BAA audits are scheduled, owners assigned, and completion evidenced.

1

Administrative Safeguards

Security Rule – 45 CFR §164.308

Administrative controls ensure we identify, assess, and manage risks to ePHI with clear accountability across the workforce and our partners.

  • Risk analysis

    Required

    We perform an enterprise risk analysis at least annually and whenever major changes occur, cataloging threats to ePHI across infrastructure, applications, and people.

  • Risk management program

    Required

    Mitigation plans are prioritized, funded, and tracked through closure with dashboards for leadership review.

  • Sanction policy

    Required

    Workforce disciplinary guidelines are documented, acknowledged, and enforced when privacy or security obligations are breached.

  • Information system activity review

    Required

    Security, privacy, and engineering leads jointly review audit logs, access reports, and incident metrics on a defined cadence.

  • Assigned security responsibility

    Required

    A single accountable security official oversees the HIPAA program and reports progress to executive leadership.

  • Workforce security lifecycle

    Addressable

    We enforce least-privilege onboarding, periodic access reviews, and tightly scripted offboarding procedures for every role.

  • Information access management

    Addressable

    Role-based access controls, ticketed provisioning, and documented approvals govern all ePHI systems, including clearinghouse isolation when required.

  • Security awareness & training

    Addressable

    Harper employees complete initial and annual HIPAA training, phishing simulations, and targeted modules for engineering and support teams.

  • Security incident procedures

    Required

    Our incident response plan covers detection, escalation, containment, forensics, notifications, and retrospective learning with full documentation.

  • Contingency planning

    Required & Addressable

    We maintain and test our ability to safeguard ePHI during service disruptions with documented response and recovery playbooks.

    • Data backup plan

      Required

      Automated backups are encrypted, verified daily, and replicated to a secondary region with restore drills at least twice a year.

    • Disaster recovery plan

      Required

      Runbooks define RTO/RPO targets, failover procedures, and communication templates for extended outages.

    • Emergency mode operation plan

      Required

      We prioritize critical clinical workflows under emergency conditions to ensure patients and clinicians maintain access to essential information.

    • Testing & revision procedures

      Addressable

      Tabletop and technical DR exercises feed improvement back into our documentation and automation.

    • Applications & data criticality analysis

      Addressable

      Business impact assessments rank each system handling ePHI so recovery sequencing reflects real-world priorities.

  • Program evaluation

    Required

    We conduct annual security and privacy program evaluations to validate safeguards and adjust to new threats or business changes.

  • Business associate management

    Required

    All vendors with ePHI access execute BAAs, undergo due diligence, and maintain downstream assurances for subcontractors.

  • Documentation retention

    Required

    Policies, procedures, risk analyses, training records, and incident logs are retained for no less than six years.

2

Physical Safeguards

Security Rule – 45 CFR §164.310

Physical controls protect our workplaces, workstations, and media wherever ePHI could be accessed or stored.

  • Facility access controls

    Addressable

    We operate within secured facilities, enforce badge-based entry, maintain visitor logs, and define contingency operations for alternate sites.

  • Workstation use standards

    Required

    Acceptable use requirements cover physical placement, privacy screens, and authorized functions for devices handling ePHI.

  • Workstation security

    Required

    All corporate endpoints use disk encryption, auto-lock, cable locks or secure rooms, and centralized device management.

  • Device & media controls

    Hardware containing ePHI is tracked end-to-end and sanitized or destroyed under strict procedures before reuse or disposal.

    • Disposal

      Required

      We follow NIST SP 800-88 Rev.1 guidance for crypto erase, shredding, or degaussing as applicable.

    • Media reuse

      Required

      Any device slated for repurpose undergoes verified data sanitization before leaving secure custody.

    • Accountability

      Addressable

      Asset inventories record device custody, chain of possession, and attestation of sanitization.

    • Data backup & storage

      Addressable

      Before relocation or maintenance, we create secure, retrievable copies of data to prevent accidental loss.

3

Technical Safeguards

Security Rule – 45 CFR §164.312

Technical controls embed security directly into our platform, ensuring only the right people and systems can access ePHI.

  • Access controls

    Authentication, authorization, and session governance policies are enforced across every Harper environment.

    • Unique user identification

      Required

      No shared accounts—each user has a unique ID tied to least-privilege roles and auditable approvals.

    • Emergency access procedures

      Required

      Break-glass workflows grant temporary elevated access with justifications, logging, and post-event review.

    • Automatic logoff

      Addressable

      Session timeouts, device lock policies, and MDM controls reduce exposure from unattended devices.

    • Encryption & decryption

      Addressable

      ePHI is encrypted in transit (TLS 1.2+) and at rest using centrally managed keys with rotation schedules.

  • Audit controls

    Required

    Centralized logging with immutable storage and clock synchronization captures access to ePHI and supports forensic investigations.

  • Integrity protections

    Addressable

    Checksums, signed logs, and tamper-evident storage detect unauthorized changes to critical data.

  • Person or entity authentication

    Required

    Strong authentication—including MFA for administrators and remote access—is enforced with no shared credentials.

  • Transmission security

    We prevent interception or tampering of ePHI during transmission across our services and partner integrations.

    • Integrity controls

      Addressable

      Transport protocols leverage TLS, HSTS, and certificate management with continuous monitoring for downgrade attempts.

    • Encryption in transit

      Addressable

      Plaintext protocols are disabled; all APIs, messaging, and storage replication flows require modern encryption.

4

Organizational Requirements & Documentation

45 CFR §§164.314 & 164.316

We hardwire contractual obligations and documentation practices that stand up to audits and demonstrate accountability.

  • Business associate agreements

    Every vendor with ePHI exposure signs a BAA detailing permitted uses, safeguards, breach notice timelines, and subcontractor flow-down clauses.

  • Policy & procedure governance

    Written policies live in a centralized repository with versioning, approvals, and change management triggered by environmental shifts.

  • Six-year retention

    Documentation—including risk analyses, BAAs, training records, and incident reports—is retained for at least six years from last effective date.

5

HIPAA Privacy Rule Essentials

45 CFR Part 164, Subpart E

Privacy principles shape how we collect, use, disclose, and safeguard PHI for individuals and families using Harper.

  • Minimum necessary standard

    Access and disclosures are limited to the least amount of PHI required to achieve the intended purpose.

  • TPO guidance

    Treatment, payment, and healthcare operations activities are documented so permitted uses do not require additional authorization.

  • Authorization management

    We capture, track, and honor individual authorizations for non-TPO use cases and retain documentation of revocations.

  • Notice of privacy practices

    Our NPP reflects actual practices, is delivered to users, and is posted online with revision history.

  • Identity verification

    Requestors must verify identity and authority before PHI is disclosed.

  • Individual rights fulfillment

    Processes exist to deliver access, amendments, disclosure accountings, and confidential communication preferences within regulatory timelines.

    • Access within 30 days

      Individuals can receive electronic copies of their PHI promptly through secure channels.

    • Amendment workflows

      Requests to amend PHI are evaluated, documented, and appended with statements of disagreement when denied.

    • Accounting of disclosures

      Non-TPO disclosures are logged and can be produced on demand.

    • Restrictions & confidential communications

      We honor reasonable requests for alternate contact methods and required restrictions when services are paid out-of-pocket.

  • Marketing, fundraising, & research controls

    Special rules are applied with legal review, including consideration of de-identified or limited data set options with DUAs.

  • Mitigation & safeguards

    Any improper use or disclosure triggers mitigation steps and corrective actions.

  • Workforce training & sanctions

    Privacy obligations are part of onboarding, annual refreshers, and disciplinary processes for violations.

  • Special category handling

    Stricter federal and state requirements—such as 42 CFR Part 2 for SUD records—are layered into system controls as applicable.

  • Complaint intake & non-retaliation

    Individuals have clear channels to submit privacy complaints and we prohibit retaliation for doing so.

6

Breach Notification Rule

45 CFR §§164.400–414

Prepared playbooks ensure swift decision-making, communication, and documentation for any suspected breach of unsecured PHI.

  • Breach risk assessment

    Each incident undergoes a documented risk assessment addressing data sensitivity, unauthorized parties, likelihood of access, and mitigation.

  • Unsecured PHI safe harbor

    We align encryption and destruction standards with HHS guidance to minimize scenarios that require notification.

  • Individual notification

    When required, affected individuals are notified without unreasonable delay and no later than 60 days with all mandated content.

  • HHS reporting

    We report breaches affecting 500 or more individuals within 60 days and log smaller incidents for annual submission.

  • Media notice

    If an incident impacts 500+ residents in a jurisdiction, we coordinate timely media notifications.

  • Business associate coordination

    Business Associates must notify us promptly with all relevant details so we can meet our obligations.

  • Incident documentation

    All assessments, decisions, notifications, and remediation steps are retained for at least six years.

7

Vendor & Third-Party Management

We extend HIPAA safeguards to every partner that touches ePHI through rigorous onboarding, oversight, and offboarding controls.

  • Vendor inventory & BAAs

    Every service provider that creates, receives, maintains, or transmits ePHI is cataloged and covered by an executed BAA, including downstream obligations.

  • Risk-based due diligence

    Security questionnaires, certifications (SOC 2, HITRUST), and control validations inform onboarding decisions.

  • Data sharing controls

    Vendors receive the minimum necessary access, and analytics or telemetry tools are only enabled when contractual protections and documented need exist.

  • Offboarding & attestations

    Access is terminated promptly at contract end and vendors must attest to data return or destruction.

8

Technical Baseline

Cloud & Platform Controls

Cloud-native guardrails ensure our infrastructure stays hardened, observable, and resilient against evolving threats.

  • Encryption at rest

    Managed keys reside in hardened KMS/HSM services with separation of duties and rotation policies.

  • Encryption in transit

    TLS is enforced end-to-end with deprecated ciphers disabled and private connectivity options for internal services.

  • Identity & access

    MFA, least-privilege IAM roles, periodic access reviews, and break-glass accounts protect our cloud tenants.

  • Logging & monitoring

    Logs aggregate centrally with alerting for anomalous access and long-term immutable storage.

  • Vulnerability management

    Regular patch cycles, automated scanning, and penetration tests feed our remediation backlog.

  • Endpoint security

    EDR, anti-malware, and full-disk encryption are enforced on all laptops with MDM for BYOD controls.

  • Network security

    Segmentation, WAF policies, rate limiting, and DDoS protections safeguard public and internal interfaces.

  • Secrets management

    Application secrets live in vaulted stores with rotation automation—never in code repositories.

  • Secure SDLC

    Code review, dependency scanning, SAST/DAST, and infrastructure-as-code guardrails are embedded into our pipelines.

  • Backups & disaster recovery

    Backups are automated, encrypted, and replicated across regions with periodic restore testing.

  • Data lifecycle management

    Retention schedules, deletion workflows, and NIST 800-88 aligned sanitization cover the full data lifecycle.

  • Remote work protections

    Approved devices, secure Wi-Fi/VPN usage, and hardening standards support our distributed workforce.

9

De-Identification & Data Minimization

We embrace data minimization principles so innovation never outpaces privacy protections.

  • De-identified data first

    Whenever feasible, secondary use cases rely on Safe Harbor or Expert Determination techniques to remove identifiers.

  • Limited data set governance

    When de-identification is not practical, limited data sets are paired with executed Data Use Agreements.

  • Minimum necessary enforcement

    Internal and external disclosures are scoped to the least amount of data required.

10

Training, Awareness & People

Our people are our front line—ongoing education and accountability keep privacy and security top of mind.

  • HIPAA onboarding & annual refreshers

    Every workforce member completes HIPAA and security training when hired and annually thereafter, with specialized paths for technical staff.

  • Phishing & security awareness

    We run regular phishing simulations, just-in-time education, and communications that reinforce emerging risks.

  • Onboarding & offboarding checklists

    Access grants, NDA attestations, equipment assignment, and device return are all tracked through checklists.

  • Sanctions & accountability

    Our disciplinary policy is exercised when expectations are not met, reinforcing the seriousness of HIPAA obligations.

11

Incident Response & Reporting

Prepared responders, clear communications, and regulator-ready processes minimize impact when issues arise.

  • Documented incident response plan

    Roles, severity levels, forensic preservation, and communication workflows are defined and tested.

  • Tabletop exercises

    At least annually we run realistic tabletop scenarios and capture lessons learned.

  • External coordination

    Contacts with law enforcement, regulators, and communication partners are maintained with ready-to-send templates.

12

Evaluation & Continuous Improvement

Feedback loops ensure our program evolves alongside technology, threats, and regulatory expectations.

  • Periodic program evaluations

    Security and privacy leaders review program maturity, control effectiveness, and regulatory alignment at planned intervals.

  • Internal audits & access reviews

    We audit policy adherence, entitlement reviews, and log monitoring to confirm controls are operating as intended.

  • Management review & KPIs

    Executives receive dashboards tracking open risks, time to patch, incident MTTR, and training completion.

FYI

Preparing for Upcoming HIPAA Updates

Even before rulemaking is finalized, we are adapting to the 2025 HIPAA Security Rule NPRM to stay ahead of expectations.

  • Proactive readiness for proposed requirements

    Mandatory MFA, asset inventories, enhanced risk assessments, formalized incident response, vendor oversight, and network testing are already on our roadmap with owners assigned.

Records

Evidence & Record Retention

Comprehensive evidence backs every safeguard so we can demonstrate compliance for at least six years.

  • Program artifacts on file

    Policies, BAAs, data maps, risk analyses, remediation plans, training logs, access reviews, audit log reviews, incident records, breach notifications, backup and DR tests, vendor assessments, media sanitization certificates, and audit reports are retained with clear ownership.

Compliance you can trust

Our HIPAA program is continuously audited, improved, and backed by executive oversight. Need more detail? Reach out to our privacy team for policy copies, audit reports, or to schedule a security review.

Contact our privacy team