Use these planning areas to explore the scope with your team. They are discussion topics—not a universal compliance checklist or a promise that every service is included.
01 / INFORMATIONKnow what enters the system.
+
Inventory every form, upload, booking tool, chat service, API, notification, log, and export. Decide which information is necessary for each task and where it may be collected. A diagnosis is not the only potentially sensitive field: identities, appointment details, and free-text messages also need careful review.
What we define together
A data-flow map, field inventory, approved destinations, retention decisions, and named owners.
02 / CONTRACTSReview the vendor chain.
+
Assess the exact service, product tier, configuration, subcontractors, and contractual responsibilities. A general security statement is not a substitute for reviewing the arrangement. Where a cloud provider handles ePHI on a regulated entity’s behalf, a BAA is required; keeping data encrypted without holding the key does not remove that obligation. HHS cloud guidance.
What we define together
An approved vendor register, applicable BAAs, covered services, and documented exclusions.
03 / INTAKEKeep sensitive intake in the right place.
+
Separate ordinary business inquiries from patient workflows. Plan sensitive submissions in an approved system, including attachments, validation, routing, staff access, and failure handling. Do not put health details in URLs, ordinary notification emails, analytics events, or a public CMS. A warning beside a general form does not secure its infrastructure.
What we define together
Field-by-field review, appropriate intake tooling, recipient routing, and safe notification wording.
04 / ACCESSGive each person appropriate access.
+
Scope individual accounts, role-based permissions, multifactor authentication, account recovery, session controls, and prompt removal of former staff. Review administrators, contractors, service accounts, and API credentials separately. Plan how access is approved and periodically reviewed.
What we define together
An access matrix, authentication requirements, credential handling, and onboarding/offboarding procedures.
05 / VISIBILITYRecord useful events without exposing records.
+
Plan audit events for relevant access and administrative actions, with protected logs and clear review ownership. Keep sensitive form values out of error reports, session recordings, and routine debugging. Define what is logged, who can read it, and how long it is retained.
What we define together
An event inventory, log access controls, redaction rules, and an escalation owner.
06 / TRACKINGTreat analytics as a data decision.
+
Review pixels, tag managers, embedded media, chat, heatmaps, session replay, and advertising integrations before activation. HIPAA obligations depend on the information disclosed and context; not every public page visit automatically constitutes PHI. A cookie banner alone does not resolve an impermissible disclosure. HHS tracking guidance, including the court limitation.
What we define together
An approved tracking map, exclusions for sensitive journeys, and reviewed disclosure/authorization requirements.
07 / RESILIENCEPlan recovery before it is needed.
+
Discuss encrypted backups, separation of access, restore testing, agreed recovery objectives, dependency outages, and alternative contact routes. A successful backup job is not proof that a restore works. Confirm how the organization continues essential workflows during an interruption.
What we define together
Backup scope, restore evidence, recovery responsibilities, and a downtime communication plan.
08 / OPERATIONSMaintain the whole environment.
+
Define updates, dependency review, vulnerability handling, staging controls, secret management, and change approval. Use synthetic information for design and testing. Keep production records out of demos, screenshots, support tickets, and development copies unless a separately approved process permits their use.
What we define together
A maintenance schedule, change records, testing boundaries, and a documented support route.
09 / RESPONSEMake escalation unambiguous.
+
Agree who investigates suspected exposure, preserves evidence, coordinates vendors, and makes required notification decisions. Technical incident response and legal breach assessment are related but distinct responsibilities. Response commitments and coverage must be written into the engagement.
What we define together
An incident contact tree, reporting route, provider dependencies, and approved response procedures.
10 / GOVERNANCEMake privacy an operating responsibility.
+
Assign content and privacy owners. Review notices, patient rights routes, retention, deletion, and special workflows with the organization’s qualified advisers. Identify other applicable federal, state, or sector requirements rather than assuming HIPAA is the only consideration.
What we define together
Approved notices, records-handling policies, accountable reviewers, and a recurring review process.
11 / INCLUSIONDesign for stressful, real-world visits.
+
Plan plain language, readable contrast, visible keyboard focus, usable error messages, zoom/reflow, meaningful labels, and accessible authentication. Agree an accessibility target such as WCAG 2.2 AA and test representative journeys with appropriate manual and assistive-technology checks. W3C accessibility guidance.
What we define together
An agreed test plan covering desktop, tablet, mobile, keyboard operation, forms, and third-party handoffs.
12 / CONTENTBuild trust with accountable information.
+
Use approved credentials, accurate locations, clear service descriptions, editorial review dates, and appropriate authorship. Plan translations, insurance/payment information, practical visit guidance, and emergency-use notices with the organization. Publish only verified claims; public content and patient records belong in different workflows.
What we define together
A content model, clinical review ownership where needed, migration map, and publishing permissions.