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Is Cloudflare a HIPAA compliant cloud vendor?

Is Cloudflare a HIPAA compliant cloud vendor?

We've been seeing more vendors, customers, and prospects asking about HIPAA compliant services. Since Paubox is a Business Associate to thousands of customers, we’ve been wondering if they are able to use Cloudflare in a HIPAA compliant manner.

We know the HIPAA industry is vast, so we can empathize with just how many people need to use cloud services in this sector. Today we will determine if Cloudflare offers HIPAA compliant service or not.



Cloudflare is a web infrastructure security company that provides content delivery network services (CDN). They also specialize in Distributed Denial of Service (DDoS) mitigation, internet security, and distributed Domain Name Server (DNS) services. The company is headquartered in San Francisco.


What is a Business Associate?

A Business Associate is a person or company that performs certain functions or activities that involve the use or disclosure of protected health information (PHI) for a Covered Entity. In a nutshell, the role of a Business Associate is to help Covered Entities comply with the HIPAA Privacy Rule

Read full article: What does it mean to be a Business Associate?


Business Associate Agreement provisions

If a Business Associate provides services to a Covered Entity, then a Business Associate Agreement (BAA) must be in place. A BAA is a written contract between a Covered Entity and a Business Associate and is required by law for HIPAA compliance. At a minimum, a Business Associate Agreement contains 10 provisions.

Read full article: Business Associate Agreement Provisions


Cloudflare and the Business Associate Agreement

We checked the Cloudflare site for mention of their ability to sign a Business Associate Agreement (BAA). However, we were not able to find any relevant information on their site regarding their ability to sign a BAA. For example, while the Cloudflare Compliance page mentioned PCI DSS, SOC 2, and SOC 3 reports, there was no mention of their stance on HIPAA compliance. In addition, their Terms of Service and Privacy Policy pages also turned up no relevant results.


Does Cloudflare offer HIPAA Compliant Service?

The Business Associate Agreement (BAA) is a key component to HIPAA compliance between a Covered Entity and a Business Associate. We were able to learn the following about Cloudflare and its stance on HIPAA compliance:
  • We could not find any mention of HIPAA or a BAA on the Cloudflare Compliance page.
  • We also could not find any mention of HIPAA or a BAA on their Privacy Policy and Terms of Service pages.


Conclusion: Cloudflare makes no mention of their ability to sign a BAA. We therefore conclude they should not be used as a HIPAA compliant cloud service.


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