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Biometric data, such as fingerprints or facial recognition, becomes Protected Health Information (PHI) in healthcare when linked to an individual's health records, treatment, or access to medical facilities. Healthcare organizations must store it in compliance with HIPAA because HIPAA regulates the protection and use of PHI, ensuring patient privacy, data security, and legal compliance.

Related: HIPAA Compliant Email: The Definitive Guide


Identifying biometric data in healthcare

Biometric data refers to unique physical or behavioral characteristics that can be used for identification or authentication. These characteristics include fingerprints, palm prints, iris scans, facial recognition, voice recognition, and DNA. In healthcare, this data is often tied to an individual's health records or treatment, making it PHI and subject to HIPAA regulations.


HIPAA compliant storage requirements

HIPAA sets stringent requirements for safeguarding PHI, including biometric data. To achieve compliance, healthcare organizations should follow these steps:

  1. Data classification and inventory: Begin by classifying and inventorying all biometric data within your healthcare organization. Understand where it's collected, used, and stored. Identify who has access to this data and the purposes for which it's used.
  2. Risk assessment and mitigation: Conduct a risk assessment to identify potential vulnerabilities in your biometric data storage and handling practices. Consider factors such as physical security, data transmission, and access controls. Once identified, implement risk mitigation strategies to address these vulnerabilities effectively.
  3. Implementing encryption and access controls: Encrypt biometric data in transit and at rest using encryption algorithms. Ensure that only authorized personnel have access to the encryption keys. Implement robust access controls, limiting access to biometric data to individuals who require it for their job functions. Use role-based access control to enforce the principle of least privilege, granting access only to necessary personnel.
  4. Develop and enforce data handling policies: Develop clear policies and procedures for handling biometric data. Define who can access, modify, or delete biometric data and under what circumstances. 
  5. Regular auditing and monitoring: Maintain comprehensive audit logs of all biometric data access and related activities. Regularly review and analyze these logs to detect any unauthorized or suspicious activities. 
  6. Incident response planning: Develop an incident response plan specific to biometric data breaches or unauthorized access. Outline the steps to take in the event of a security incident, including containment, notification, investigation, and corrective actions. 

Learn more:  Is biometric data PHI? 


Vendor considerations

  1. Business Associate Agreements (BAAs): When your organization shares biometric data with a third-party vendor, you must have a business associate agreement (BAA) in place. 
  2. Vendor assessment: Before entering into a partnership with a vendor, conduct a thorough assessment of their security practices and HIPAA compliance. This assessment should include a review of their policies, procedures, and infrastructure related to biometric data handling. 
  3. Data encryption: Verify that the vendor employs robust encryption methods to secure biometric data during transmission and storage. 
  4. Access controls: Inquire about the vendor's access control measures. Ensure they restrict access to biometric data to authorized personnel and employ role-based access control to minimize the risk of unauthorized access.
  5. Data ownership and control: Clearly define data ownership and control within the BAA. Ensure that your organization retains control over the biometric data and has the authority to dictate how it is used, accessed, and disposed of, even when it's in the custody of the vendor.
  6. Compliance audits: Periodically audit your vendors to ensure ongoing compliance with HIPAA regulations. 

Related: Balancing convenience and privacy with biometric authentication

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