HIPAA readiness for Adobe Experience Manager as a Cloud Service hipaa-readiness-for-adobe-experience-manager-as-a-cloud-service

WARNING
The contents of this document do not constitute legal advice and are not meant as a substitute for legal advice.
Consult your company’s legal department for advice concerning HIPAA regulations.
NOTE
For more information about Adobe’s response to privacy issues, and what this means for you as an Adobe customer, see:

For Adobe Experience Manager (AEM) as a Cloud Service, Adobe is providing documentation to help you understand HIPAA readiness. It can help you become compliant with these regulations.

Health Insurance Portability and Accountability Act (HIPAA) health-insurance-portability-and-accountability-act-hipaa

The Health Insurance Portability and Accountability Act (HIPAA) the-health-insurance-portability-and-accountability-act-hipaa

The HIPAA Privacy, Security, and Breach Notification Rules establish important protections for individually identifiable health information known as Protected Health Information (PHI).

Under HIPAA, a covered entity is a healthcare provider, health plan, or a healthcare clearinghouse. A business associate is an entity that provides services to a covered entity that involves access to PHI. The HIPAA Privacy and Security Rules require that a covered entity obtain written assurances from a business associate in the form of a Business Associate Agreement (BAA) requiring the business associate to safeguard the privacy and security of the Covered Entity’s PHI.

Providing PHI to Adobe providing-phi-to-adobe

Adobe acts as a Business Associate for its HIPAA-ready Services, listed under HIPAA readiness of services in AEM as a Cloud Service.

Customers that license any Adobe HIPAA-ready Service to process PHI must have the correct license and a signed BAA with Adobe.

IMPORTANT
Customers are not permitted to create, receive, maintain, or transmit PHI through Adobe products and services that are not designated as a HIPAA-ready Services or without the appropriate license to use a HIPAA-ready Service.

HIPAA Shared Responsibilities hipaa-shared-responsibilities

Adobe HIPAA-ready Services rely on a shared responsibility security model, requiring the customer and Adobe each to bear distinct responsibilities for maintaining the security of PHI. Under this shared security model, Adobe relies on the customer to use and configure the HIPAA-ready Services consistent with HIPAA.

For more information on executing an Adobe BAA for HIPAA-ready Services, please contact your Adobe sales representative or customer success manager.

IMPORTANT
Disclaimer:
Customer is responsible for their use of Adobe HIPAA-ready Services and for ensuring that the Adobe HIPAA-ready Services meet their compliance requirements.

For more information, see HIPAA and Adobe Products and Services in the Adobe Trust Center.

HIPAA terminology hipaa-terminology

The following table describes how AEM services are categorized for HIPAA usage.

HIPAA readiness
Description
HIPAA-ready
Designed to process PHI when configured appropriately and used with a BAA.
Not HIPAA-ready
Not designed to process PHI and must not be used in HIPAA-related use cases.
NOTE
HIPAA readiness classifications are based on the intended functionality of each service and may change over time.
Customers should refer to the most current documentation and applicable contractual terms when planning HIPAA-related deployments.

HIPAA readiness of services in AEM as a Cloud Service hipaa-readiness-of-services-in-aem-as-a-cloud-service

The following table describes which AEM services are HIPAA-ready and which services may be used alongside them. HIPAA-ready services require the purchase of Extended Security for Healthcare, as described under Additional Requirements.

Product/Capability
Service(s)
HIPAA readiness
AEM Sites
AEM Sites, AEM Publish, Edge Delivery Services
HIPAA-ready
AEM Sites
Universal Editor
Not HIPAA-ready
[1] Can be added to an Extended Security Program when no PHI is introduced.
AEM Sites Optimizer
Sites Optimizer
Not HIPAA-ready
[1] Can be added to an Extended Security Program when no PHI is introduced.
AEM Assets
AEM Assets
HIPAA-ready
AEM Assets
Content Hub
Not HIPAA-ready
[1] Can be added to an Extended Security Program when no PHI is introduced.
AEM Assets
Brand Portal
Not HIPAA-ready
AEM Assets
Dynamic Media OpenAPI
Not HIPAA-ready
[1] Can be added to an Extended Security Program when no PHI is introduced.
AEM Assets
Dynamic Media Scene 7
Not HIPAA-ready
AEM Forms
AEM Forms, Authentication Facade Service, PDF Utility Service
HIPAA-ready
AEM CIF
Commerce Integration Framework
Not HIPAA-ready
AEM Cloud Manager
AEM Cloud Manager, Release Orchestrator, Release Toggles, Release Validator
HIPAA-ready
AEM Cloud Manager
Software Distribution
Not HIPAA-ready
[1] Can be added to an Extended Security Program when no PHI is introduced.
AEM Guides
AEM Guides
Not HIPAA-ready
LLM Optimizer
LLM Optimizer
Not HIPAA-ready
[1] Can be added to an Extended Security Program when no PHI is introduced.
NOTE
[1]
For not HIPAA-ready services that are indicated as can be added to an Extended Security program, customers must ensure that PHI is not routed to or stored in these services.
Introducing PHI into a service that is not HIPAA-ready may result in non-compliance.

Additional Requirements additional-requirements

Services listed as HIPAA-ready require the purchase of Extended Security for Healthcare.

When Extended Security for Healthcare is purchased, there is the requirement that:

  • the products selected for that program are HIPAA-ready (as listed in the table),
  • Extended Security for Healthcare has been purchased for each product; this ensures sufficient Cloud Manager Credits,
  • Extended Security for Healthcare is applied at the time of program creation.

If the requirements are fulfilled, Extended Security for Healthcare can be applied upon AEM program creation; see Setup for details.

NOTE
For more details on provisioning, and pricing, reach out to your sales representative.

Environments environments

HIPAA-ready does not apply to RDE (Rapid Development Environment), Dev, or Stage environments, as PHI is not allowed on these environments.

This means that you must:

  • use dummy data for development and testing purposes
  • only process PHI from production environments

The following table shows where the environment types can be supported as HIPAA-ready.

RDE
Dev
Stage
Prod
Environment Type
No
No
No
Yes

Setup setup

When you Create Production Programs, the Security tab provides the options to activate HIPAA protection.

recommendation-more-help
fbcff2a9-b6fe-4574-b04a-21e75df764ab