Securing PHI and ePHI

Organizations create and exchange enormous amounts of sensitive information every day. This is certainly true of government agencies, and of course, healthcare organizations. In healthcare, patient records move through electronic health records, laboratory systems, billing applications, email, cloud platforms, collaboration tools, medical devices, data warehouses, file shares, backups, and third-party applications. How can you deal with PHI and ePHI data protection?

What is considered PHI?

Protected Health Information, or PHI, is individually identifiable health information protected under HIPAA when it is created, received, maintained, or transmitted by a covered entity or business associate. PHI can even be a verbal exchange of information. Over time, these copies create a larger and less visible data footprint. There are many elements that comprise the PHI umbrella.

Some examples are:

• Any health data combined with identifiers like name, address, phone number, or medical record number
• Medical records and diagnoses (paper or electronic)
• Billing and insurance information
• Lab results
• eMails or messages referencing patient care

ePHI, specifically refers to the PHI that is handled or moved through electronic media.

PHI in AI Tools

AI adds a new place for PHI to hide. When staff paste clinical notes into a chatbot, use an AI to record and transcribe meetings, or connect a copilot to email and file shares, PHI flows into prompts, outputs, logs, and vendor systems that may never show up in your data inventory.

Do you know where that information is processed and stored? Many AI services route requests across regions for capacity, and failover can shift processing to data centers in other states or countries without anyone on your side noticing.

Before PHI touches an AI tool, organizations should confirm there’s a business associate agreement in place, where data is processed and retained (including during failover), whether prompts are logged or used to train models, and which subprocessors are involved. Staff using free consumer AI tools on their own (“shadow AI”) are often the biggest blind spot, because those tools typically come with no Business Associate Agreement (BAA).

Industry Challenge:

The challenge is ensuring that PHI and ePHI are identified wherever they are maintained or transmitted and that appropriate HIPAA administrative, physical, and technical safeguards are applied based on the organization’s risk analysis and the systems, people, and third parties handling the information.

Discovery & Protection:

Discovering PHI/ePHI is becoming a core cybersecurity capability. An organization cannot consistently protect information it does not know exists. If a repository containing PHI/ePHI is missing from the organization’s inventory, it may also be excluded from encryption/security requirements, access reviews, vulnerability management, logging, monitoring, backup controls, retention rules, incident response planning, and third-party risk assessments.

Effective protection therefore begins with discovery, identification, classification, and inventory—followed by appropriate safeguards, continuous monitoring, and governance.

Anvaya Solutions helps organizations identify and inventory PHI and ePHI across their environments, evaluate the safeguards protecting that information, identify potential security and compliance gaps, and establish governance processes to help maintain visibility and protection as systems and data evolve.

To learn more about how Anvaya Solutions can assist your organization with PHI/ePHI discovery, security, and governance, contact us.

Secure. Protect. Thrive!