Apple Notes is a note-taking app that allows users to create notes, organize checklists, add images and documents, and record audio. With iCloud, users can sync notes across Apple devices and collaborate with others.

Is Apple Notes HIPAA compliant? No, based on our research, Apple Notes is not HIPAA compliant for storing or syncing protected health information (PHI) through iCloud.

 

Will Apple Notes sign a business associate agreement (BAA)?

No, Apple does not offer a business associate agreement covering Apple Notes with iCloud, and therefore this use is not HIPAA compliant.

Apple’s iCloud terms and conditions prohibit covered entities and business associates from using the service to “create, receive, maintain or transmit” PHI or in any manner that would make Apple their business associate.

HHS guidance confirms that a cloud provider storing PHI on a healthcare organization’s behalf requires a BAA even when the information is encrypted and the provider cannot read it.

 

Conclusion

Apple Notes does not have a BAA covering iCloud storage and is therefore not HIPAA compliant for storing or syncing PHI through that service. Any proposed local-only use requires a separate assessment of device safeguards and backup settings, particularly because “On My iPhone” notes can be included in iCloud backups.

Learn more: HIPAA Compliant Email: The Definitive Guide

 

FAQS

What is a BAA?

A BAA is a legally binding contract establishing a relationship between a covered entity under HIPAA and its business associates. The purpose of this agreement is to ensure the proper protection of PHI as required by HIPAA regulations.

 

What is HIPAA?

HIPAA sets national standards for protecting the privacy and security of certain health information, known as PHI.

HIPAA is designed to protect the privacy and security of individuals’ health information and to ensure that healthcare providers and insurers can securely exchange electronic health information. Violations of HIPAA can result in significant fines and penalties for covered entities.

 

Who does HIPAA apply to?

HIPAA applies to covered entities, which include healthcare providers, health plans, and healthcare clearinghouses. It also applies to business associates of these covered entities. These are entities that perform certain functions or activities on behalf of the covered entity.