TL;DR
Building a browser app that handles Protected Health Information (PHI) under HIPAA requires careful planning and execution. This guide outlines key design considerations, focusing on security, access control, audit trails, data transmission, and more. It’s not exhaustive – you *must* consult legal counsel for full compliance.
Designing for HIPAA Compliance: Browser Applications
- Understand the HIPAA Rules
- Privacy Rule: Protects patient information.
- Security Rule: Defines how PHI is protected electronically. This is your main focus.
- Breach Notification Rule: Outlines requirements if a breach occurs.
- Data Security – At Rest & In Transit
- Encryption: Encrypt PHI both when it’s stored (at rest) and when it’s being sent over the internet (in transit). Use strong encryption algorithms.
- At Rest Example: Consider database-level encryption or full disk encryption for servers storing PHI.
- In Transit Example: Always use HTTPS/TLS. Ensure your SSL certificates are up to date and properly configured.
- Access Control – Who Can See What?
- Role-Based Access Control (RBAC): Implement RBAC so users only have access to the PHI they *need* for their job.
- Unique User Identification: Every user must have a unique login and password. Avoid shared accounts.
- Strong Authentication: Multi-Factor Authentication (MFA) is highly recommended, especially for privileged accounts.
- Audit Controls – Tracking Everything
- Comprehensive Logging: Log all access to PHI, including who accessed it, when, and what they did.
- Log Storage & Review: Securely store logs for a minimum of six years (check your state laws as this can vary). Regularly review these logs for suspicious activity.
- Example Log Entry: A typical log entry might include timestamp, user ID, IP address, resource accessed, and action performed.
- Data Integrity – Preventing Changes
- Prevent Unauthorized Alteration: Implement controls to prevent accidental or malicious modification of PHI.
- Digital Signatures: Consider using digital signatures for sensitive data to verify its authenticity and integrity.
- Authentication & Authorization – Secure Login
- Password Policies: Enforce strong password policies (length, complexity, rotation).
- Session Management: Implement secure session management to prevent session hijacking. Use short session timeouts and automatically log users out after inactivity.
- Example Session Timeout Configuration (Node.js with Express):
const express = require('express'); const app = express(); app.use(session({ secret: 'your-secret-key', resave: false, saveUninitialized: true, cookie: { secure: true, httpOnly: true, maxAge: 600000 } // 10 minutes }));
- Browser Security Considerations
- Cross-Site Scripting (XSS) Protection: Sanitize all user input to prevent XSS attacks. Use a Content Security Policy (CSP).
- SQL Injection Prevention: Use parameterized queries or an ORM to prevent SQL injection vulnerabilities.
- Regular Vulnerability Scanning: Regularly scan your application for known vulnerabilities using automated tools and manual penetration testing.
- Business Associate Agreements (BAAs)
- If you use third-party services (e.g., cloud hosting, analytics), ensure they are HIPAA compliant and sign a BAA with them.
- Incident Response Plan
- Develop a plan for responding to security incidents, including data breaches. This should include procedures for containment, investigation, notification, and mitigation.
Important Disclaimer: This guide provides general information only and is not legal advice. You must consult with a qualified cybersecurity professional and legal counsel to ensure your application fully complies with all applicable HIPAA regulations.