Handling PHI on hospital landing pages

Safeguarding patient privacy on hospital landing pages requires a proactive approach and adherence to strict security protocols. Hospitals can ensure compliance with privacy regulations by implementing robust encryption, access controls, and training programs while providing patients with a secure and seamless online experience.

What PHI can be included on a hospital landing page?

The HIPAA Privacy Rule defines PHI as individually identifiable health information that relates to the past, present, or future health status of an individual. This includes any information that can be linked to a specific person and that is created, received, or maintained by a covered entity, such as a hospital.

When designing a hospital landing page, compliance with HIPAA regulations avoids the inclusion of any PHI unless it's done so in a secure and compliant manner.

Here are some examples of PHI that should generally not be included on a hospital landing page:

• Patient names
• Dates of birth
• Addresses
• Medical record numbers
• Social Security numbers
• Email addresses or other contact information when associated with health information
• Any detailed descriptions of medical conditions or treatments that could potentially identify an individual

However, a hospital landing page can still provide valuable information without including PHI. Here are examples of appropriate content for a hospital landing page:

• General information about the hospital, its services, and specialties offered.
• Contact information for scheduling appointments or reaching specific departments.
• Educational resources about health conditions, wellness tips, and preventive care.
• Testimonials or reviews from patients (ensuring that no PHI is disclosed in these testimonials).
• Information about healthcare providers, their expertise, and qualifications.
• Health news, events, or community outreach programs organized by the hospital.

While these examples do not fall under PHI, it's still important to review them regularly to ensure compliance and avoid accidentally exposing sensitive information.

Read more: What are the 18 PHI identifiers?

Best practices for a landing page

PHI on a hospital landing page should be handled with the utmost care to ensure compliance with HIPAA regulations. Here are some guidelines to consider:

Encryption and security

“On December 27, 2024, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) issued a Notice of Proposed Rulemaking (NPRM) to modify the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security Rule to strengthen cybersecurity protections for electronic protected health information (ePHI),” writes the HHS.

Under these updates, HIPAA-regulated entities are required to implement encryption as part of their security plan. 

Under this requirement, it is best practice to:

• Ensure landing pages use HTTPS, which encrypts data exchanged between the user's browser and the server.
• If patients fill out forms on the site (e.g., requesting appointments or subscribing to health newsletters), these forms must be encrypted.
• Protect any backend databases storing PHI with strong encryption protocols like AES-256.

Consent and disclosure

According to a publication in the National Library of Medicine’s book on informed consent, informed consent “is to ensure that patients are fully informed about the medical procedures or treatments they are about to undergo, enabling them to make autonomous decisions about their care.” Hospitals must clearly communicate to users what information is being collected, how it will be used, and who will have access to it. Explicit consent must be obtained from users before collecting any PHI.

Data retention policies

Hospitals should have policies in place regarding the retention and disposal of PHI. 

Retention should be:

• Aligned with HIPAA rules and internal policies.
• Justified based on business or legal needs.
• Paired with secure deletion protocols.

These policies should extend to third-party services that process data on the hospital’s behalf.

Training and awareness

Landing pages are often managed by a mix of IT staff, communications teams, and digital marketers, some of whom may not be familiar with HIPAA requirements. The HIPAA Privacy Rule requires that “a covered entity must train all members of its workforce on policies and procedures […] as necessary and appropriate for the members of the workforce to carry out their functions within the covered entity.” Furthermore, the HIPAA Security Rule states that covered entities or business associates must “implement a security awareness and training program for all members of its workforce including management”.

Hospitals must ensure that all staff members who have access to PHI on the landing page are trained in HIPAA compliance and understand the importance of safeguarding sensitive information.

Audit trails

The HIPAA Security Rule technical safeguards requires HIPAA-regulated entities to “implement hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use electronic protected health information.”

These audit trails track who accessed PHI, when it was accessed, and for what purpose. This can help identify and respond promptly to any unauthorized access or breaches.

Third-party services

If using third-party services or integrations on the landing page that involve PHI, ensure that they are HIPAA compliant (have a BAA in place) and have appropriate security measures in place.

See also: 

• What does it mean to be a business associate?
• Business Associate Contracts

FAQs

What should hospitals do to ensure compliance with privacy regulations when handling PHI on landing pages?

Hospitals should stay up-to-date with HIPAA regulations and implement policies and procedures to ensure compliance. This includes regular risk assessments, documentation of security measures, and prompt response to any breaches or incidents involving PHI.

Go deeper: What is the key to HIPAA compliance

What are the potential risks of mishandling PHI on hospital landing pages?

Mishandling PHI can lead to severe consequences, including identity theft, medical fraud, compromised patient confidentiality, and regulatory penalties. Unauthorized access to or disclosure of PHI can harm patients and damage the reputation of the healthcare institution.

Read more: What are the consequences of not complying with HIPAA?

What steps should hospitals take to ensure staff members are trained in handling PHI on landing pages?

Hospitals should provide comprehensive training sessions covering HIPAA compliance, data security protocols, and best practices for handling sensitive information. Regular refresher courses and awareness programs can help reinforce the importance of patient privacy.