Is Google Hangouts HIPAA Compliant?

Is Google Hangouts HIPAA compliant? Can Google Hangouts be used by healthcare professionals to transmit and receive protected health information (PHI)?

Is Google Hangouts HIPAA Compliant?

Healthcare organizations frequently ask about Google services and HIPAA compliance, and one product in particular has caused some confusion is Google Hangouts. Google Hangouts is the latest incarnation of the Hangouts video chat system, and has taken the place of Huddle (Google+ Messenger). Google Hangouts is a cloud-based communication platform that incorporates four different elements: Video chat, SMS, VOIP, and an instant messaging service.

Google will sign a business associate agreement for G Suite, which currently covers the following Google core services

  • Gmail
  • Calendar
  • Google Drive (Includes Google Docs, Google Sheets, Google Slides, and Google Forms)
  • Apps Script
  • Keep
  • Sites
  • Jamboard
  • Google Cloud Search
  • Vault (If applicable)
  • Google Hangouts (Chat messaging)
  • Hangouts Meet

The Business Associate Agreement does not cover Google Groups, Google Contacts, and Google+, none of which can be used in conjunction with protected health information. Google also advises users to disable the use of non-core services in relation to G suite – for example YouTube, ​Blogger ​and Google ​Photos.

So, certain elements of Google Hangouts are HIPAA compliant and can be used by HIPAA covered entities without violating HIPAA Rules, provided that prior to the use of the services with PHI, the covered entity has entered into a business associate agreement with Google.

However, even with a BAA in place, not all elements of Google Hangouts are HIPAA compliant, so covered entities must exercise caution. Video chat for instance, is not covered by the BAA so cannot be used, and neither can the SMS and VOIP options.

To help make Google Hangouts HIPAA compliant, Google has released a guide for healthcare organizations.

Google Hangouts HIPAA Compliance Depends on Users

If you decide to allow the use of Google Hangouts in your organization, it important to address the allowable uses of Google Hangouts with respect to PHI through policies and procedures. Staff must be trained on the correct use of the platform, and instructed which elements of Google Hangouts can be used and which are prohibited. If video chat is important for your organization, you should seek a HIPAA-compliant alternative platform.

As we have mentioned in a previous post, simply obtaining a BAA from Google is no guarantee of HIPAA compliance – that will depend on how Google services are configured and how they are used – See this page for further information of G Suite HIPAA Compliance.

Don’t Forget to Implement Additional Safeguards for Mobile Devices

One area where HIPAA-covered entities could easily violate HIPAA Rules is the use of Google Hangouts on mobile devices. Google does have excellent security controls that can alert users to potential unauthorized access of their Google account. These should be configured to ensure inappropriate access attempts are identified rapidly. Controls should also be implemented on mobile devices to ensure that the devices are protected in case of loss or theft.

Access controls on the device should be implemented to prevent the device, and any ePHI stored on it, from being easily accessed. Policies and procedures should also be developed to ensure lost and stolen devices are reported promptly, and actions taken to secure accounts. It is also recommended to implement controls that allow lost and stolen devices to be located, locked, and remotely wiped.

Author: Steve Alder has many years of experience as a journalist, and comes from a background in market research. He is a specialist on legal and regulatory affairs, and has several years of experience writing about HIPAA. Steve holds a B.Sc. from the University of Liverpool.