May 21, 2026

Privacy Rule: PHI Handling & Patient Rights

# Privacy Rule: PHI Handling & Patient Rights This module covers the HIPAA Privacy Rule requirements relevant to our work as a Business Associate. ## Permitted uses and disclosures As a Business Associate, we may use or disclose PHI only as permitted by our customers' BAA and HIPAA: **Permitted internal uses:** - Operating and improving the platform on behalf of the customer - Troubleshooting customer-reported issues (minimum necessary) - Generating audit and compliance reports for the customer - Backup, recovery, and business continuity operations **Permitted external disclosures:** - To subprocessors under signed BAAs (see Subprocessor Registry) - As required by law (subpoena, court order — Privacy Officer notifies customer unless prohibited) **Prohibited uses — zero exceptions:** - Marketing, fundraising, or sale of PHI - Research without explicit customer authorization - Sending PHI to public AI/LLM APIs (see LLM Routing Policy) ## Minimum necessary standard When accessing or disclosing PHI, limit it to the minimum required. Practically: - Access only records you need for the current task - Do not pull bulk PHI extracts without Privacy Officer approval - The audit log captures every PHI view ## PHI in operational channels - **Email**: Never send PHI via unencrypted email. Use encrypted channels or the platform's messaging module. - **Chat/Slack**: PHI in Slack is generally prohibited. Escalate to the platform if a customer needs to share PHI. - **Code & tests**: Never include real PHI in source code, test fixtures, or documentation. Use synthetic data only. - **Databases**: Personal dev databases must not contain real PHI. Use the dev seed tool. ## Attestation Completing this module confirms you understand Privacy Rule requirements for PHI handling.