As healthcare organizations rush to modernize, many migrate to the cloud first and think about compliance later. This reactive approach often leads to costly retrofits, frantic policy changes, and significant security holes that can put sensitive patient data at risk. A smarter, more secure strategy is to adopt a “HIPAA-by-Design” philosophy, embedding compliance into the very foundation of your cloud infrastructure.
This proactive mindset isn’t just about checking boxes on a list; it’s about creating a reliable and resilient cloud environment that protects electronic protected health information (PHI) from the ground up. By building with HIPAA compliance at the forefront of the design process, healthcare providers are able to avoid future headaches, reduce costs, and focus on what truly matters: delivering exceptional patient care.
This article will introduce the concept of HIPAA-by-design, and demonstrate how Atlantic.Net cloud computing services are helping support HIPAA compliance to a large customer base of HIPAA covered entities. Highlighting the potential risks of failing to ensure security of patient sensitive information.
Who Needs to Be HIPAA Compliant? Understanding Covered Entities
The first step in any compliance journey is understanding where you fit. The Health Insurance Portability and Accountability Act (HIPAA) and its subsequent HIPAA rules apply to two main groups:
- Covered Entities: These are the frontline organizations in healthcare. The category includes health plans, healthcare clearinghouses, and healthcare providers who electronically transmit health information. If your organization provides treatment, payment, or operations in healthcare, you are likely a covered entity.
- Business Associates: This group includes any vendor or subcontractor that creates, receives, maintains, or transmits PHI on behalf of a covered entity. This is where your cloud service provider (CSP) comes in, and its exactly what Atlantic.Net provide to our HIPAA clients. When you store PHI in a cloud computing environment, the provider becomes one of your business associates.
This relationship is critical. You cannot simply move patient data to any cloud storage solution. You must partner with a cloud hosting provider that understands its role and is willing to formalize its responsibilities, provide physical security, a compliant cloud based service, network and compute that exceeds HIPAA standards, and of course HIPAA compliant cloud storage that meets industry standards.
Healthcare Providers – Business Associate Agreement (BAA)
Before a single byte of electronic protected health information (ePHI) is moved to the cloud, a Business Associate Agreement (BAA) must be in place. A BAA is more than a formality; it’s a legally binding contract that outlines how your chosen cloud service provider will protect sensitive data.
The BAA details the provider’s responsibilities for safeguarding ePHI, the permissible uses of the data, breach notification procedures, and requirements for subcontractors. Without a signed BAA, your organization is not HIPAA compliant, no matter how secure the provider’s infrastructure claims to be. A reputable provider will offer a BAA as a standard component of their HIPAA compliant cloud services.
At Atlantic.Net, we understand our role in the shared responsibility model of compliance. In this model, Atlantic.Net secures the underlying cloud infrastructure, while you, the client, are responsible for securing the data and applications you place in the cloud, including managing user access and configuring security settings.
Atlantic.Net works closely with our clients to help them achieve compliance, we can guide and advise you how to prepare your systems, and how to keep data safe when other covered entities process phi. We provide a comprehensive BAA for all our HIPAA-compliant hosting clients, establishing a clear framework of accountability from day one.
The HIPAA Privacy Rule and Security Rule
Every healthcare professional needs to know about these fundamental rules. These core HIPAA guidelines, which have now been significantly strengthened by the Health Information Technology for Economic and Clinical Health (HITECH) Act, are principally divided into two main rules that dictate the “what” and “how” of protecting patient information.
HIPAA Privacy Rule
The HIPAA Privacy Rule establishes national standards for protecting individuals’ medical records and other identifiable health information. It focuses on what data is protected and sets limits on its use and disclosure without patient authorization. It also gives patients rights over their own health information, including the right to examine and obtain a copy of their health records.
Security Rule
While the Privacy Rule sets the standards, the HIPAA Security Rule dictates how to protect ePHI. This rule is more technical and flexible, allowing organizations to implement technologies and processes appropriate for their size and complexity.
The Security Rule is built on three categories of safeguards:
Technical Safeguards:
These are the technology and related policies used to protect ePHI and control access to it. At Atlantic.Net, we implement a suite of managed services that directly address these requirements.
To enforce strong access controls and user authentication, we deploy Multi-Factor Authentication(MFA). For data in transit, our Encrypted VPN and mandatory TLS Certificates ensure information is unreadable to unauthorized parties. For data at rest, we utilize strong encryption across our Encrypted Storage and Encrypted Backup solutions.
Network security is hardened with our Fully Managed Firewall Appliance, which is configured and maintained by our experts to block malicious traffic. To meet the need for continuous oversight, our Log Inspection System provides the detailed audit trails necessary to track all access and activity involving sensitive information, forming a complete technological defense for your data.
Physical Safeguards:
These focus on securing the physical locations where ePHI is stored. While you manage your applications, Atlantic.Net secures the underlying infrastructure.
Your data resides in our world-class, NIST certified data centers, which are protected by stringent physical access controls, including 24/7/365 security personnel, biometric scanners, and continuous video surveillance.
Our facilities are designed for resilience and security, a fact that is independently verified by our SOC 2 Type II and SOC 3 Type II certifications. These reports validate that our controls for security and availability meet the highest industry standards, ensuring your ePHI is physically protected from environmental threats and unauthorized access.
Administrative Safeguards:
This is the operational side of security, such as the policies and procedures that govern your compliance strategy. While you are responsible for your own internal policies and risk management, partnering with Atlantic.Net strengthens your administrative posture.
As mentioned previously, the partnership is founded by the Business Associate Agreement (BAA), an essential administrative control that formally defines our responsibilities in protecting your ePHI.
Our entire hosting environment is HIPAA and HITECH audited, giving you confidence that our own procedures are sound. Our IT professionals are available 24/7 to provide expert support, acting as an extension of your team to help you with any the complexities of maintaining a compliant cloud environment.
Architecting a HIPAA Compliant Cloud Environment
Building a HIPAA compliant cloud from the ground up requires a multi-layered approach that addresses all aspects of the Security Rule. This means partnering with a cloud provider that offers more than just server space; you need a partner with a deep understanding of the HIPAA requirements.
Here are the essential components for your HIPAA compliant storage architecture:
Private Hosted Environment:
Your server infrastructure should be completely isolated from other tenants. At Atlantic.Net, our experienced engineers configure private, segmented environments to ensure the integrity and confidentiality of your data. We recommend dedicated hosts for HIPAA compliance, but you can also achieve this with bare metal servers or with our cloud hosting options.
Managed Firewalls:
A WAF firewall is a non-negotiable requirement. We combine perimeter and server-side firewalls, which we deploy, maintain, and manage to protect against evolving threats. WAFs are dynamically updated which means they are protected against zero-day threats immediately. The rules we apply to the WAF harden your environment from even the most advanced threats.
Encrypted VPN and Storage:
All ePHI must be encrypted, both at rest in secure cloud storage and in transit over your network. These protects ensure your patient data is always protected, combine this with robust access controls and you ePHI is in safe hands. Atlantic.Net ensures your VPN and storage volumes meet the HIPAA encryption standards expected from a cloud storage provider.
Multi-Factor Authentication (MFA):
Verifying user identity is crucial for preventing unauthorized access. We offer multi-factor authentication solutions to add a critical layer of security to your access management protocols. Its essential to train your employees to follow the best practice security standards when managing user accounts and access controls. Atlantic.Net are happy to help guide you to create a strong security posture.
Onsite and Offsite Backups:
HIPAA mandates that you have a reliable data backup and a disaster recovery plan. We provide fully managed daily backups, with both onsite copies for rapid recovery and offsite copies for protection against catastrophic events. Our HIPAA compliant cloud is redundant and can be configure to offer failover for your critical applications and services to ensure continuously service in the event of a disaster.
Continuous Monitoring and Logging:
To stay compliant, one of the regular security assessments you must achieve is being able to track who has accessed ePHI and when. Our SIEM log inspection systems and real-time monitoring provide the detailed audit trails necessary to these HIPAA regulations.
Why a “HIPAA-by-Design” Approach Leads to Better Patient Outcomes
When data security is integral to your IT operations, it creates a stable foundation for innovation. A secure HIPAA compliant cloud ensures that data is available when and where healthcare teams need it, without compromising patient privacy. This reliability allows care providers to use technologies such as telehealth platforms and data analytics with confidence, leading to more informed decisions and ultimately, better outcomes for patients.
Achieving this level of trust and innovation requires a partnership with a provider that has a long-standing commitment to security and compliance. For 30 years, Atlantic.Net has been a strategic partner to organizations with mission-critical compliance needs. Our HIPAA-Compliant Hosting solutions are built on a foundation of security and stability, backed by our world-class data center infrastructure and a 100% Uptime SLA. Our environment is not only HIPAA and HITECH audited but has also achieved SOC 2 Type II and SOC 3 Type II certifications.
From fully managed firewalls and encrypted backups to 24/7/365 high-touch support from our compliance specialists, we provide the technical safeguards and expert guidance you need to build and maintain a secure and HIPAA compliant infrastructure. Don’t let compliance be an afterthought. Contact an Atlantic.Net advisor today to build your HIPAA compliant cloud the right way, right from the start.