Why internal emails must be HIPAA compliant

When it comes to HIPAA compliance, most healthcare organizations tend to focus on external communications—messages sent to patients, vendors, or other outside parties. While this is critical, one equally important aspect often gets overlooked: internal emails.

Sensitive patient data, or protected health information (PHI), flows just as often inside a healthcare organization as it does outside. From one doctor emailing lab results to another, to an administrator sending billing records for review, to a nurse asking a colleague for updates on a patient’s care plan, internal communication is constant. If these emails aren’t handled correctly, they can quickly become a weak point in compliance and a target for exploitation. In fact, according to Ponemon’s 2020 Insider Threats Report, as quoted by the HHS Cybersecurity Program, “61% of data breaches involving an insider are primarily unintentional, caused by negligent insiders.”

Reasons for HIPAA compliant internal emails

Internal emails are not “safer” simply because they stay within an organization. They carry just as much risk as external emails because breaches from within often go unnoticed for longer and can involve employees with legitimate access credentials. Here are the key reasons compliance is non-negotiable:

Protecting PHI

The foundation of HIPAA is the protection of protected health information (PHI). This includes any information that can identify a patient, such as names, addresses, medical histories, diagnoses, lab results, or insurance details. Whether that information is shared externally or between staff members internally, HIPAA requires that it be safeguarded.

An internal email sent without encryption could still be intercepted, misdirected, or accidentally forwarded. Once PHI is exposed, the organization is responsible for the breach.

Regulatory compliance

HIPAA’s Privacy Rule and Security Rule do not make distinctions between internal and external communication. That means every internal email containing PHI must follow the same safeguards as external ones: encryption, secure servers, access controls, and audit trails.

Failing to comply can result in costly penalties. Civil fines for HIPAA violations can range from $141 to $71,142 per violation, with an annual maximum of over $2 million per category of violation. In severe cases, criminal charges may also apply.

Maintaining patient trust

Patients assume their personal health data is protected at all times, not just when doctors talk to them directly. If an internal breach occurs, patients often see little difference between that and an external leak. Either way, their trust is broken. In fact, according to MedCity News, “Between April 2020 and January 2024, patient trust in the health system has declined by 30%. Over time, poor communication and negative healthcare experiences have left patients frustrated, diminishing the trust they have in stakeholders across the care continuum – from providers to payers.”

Maintaining strict HIPAA compliance for internal emails reassures patients that their providers treat their privacy with the utmost seriousness. In healthcare, trust is currency. Without it, patient engagement and satisfaction plummet.

Organizational accountability

HIPAA requires healthcare organizations to demonstrate accountability by showing that reasonable safeguards are in place to protect PHI. Internal emails are often reviewed during compliance audits and investigations.

For example, if a breach occurs, investigators from the Department of Health and Human Services (HHS) may ask:

• Were emails encrypted?
• Were only authorized staff allowed to send and receive PHI internally?
• Was staff properly trained on email security?

Organizations that fail these checks often face higher penalties, while those with strong safeguards may qualify for reduced penalties.

Insider threats are real

Breaches are not only caused by hackers but also by insiders, whether malicious or accidental. 

According to the Ponemon Institute’s 2020 Insider Threats Report:

• “Malicious Insiders – 14% of Insider Threat Incidents
• Negligent Insiders – 61% of Insider Threat Incidents
• Negligent Insiders (credentials stolen) – 25% of Insider Threat Incidents”

A distracted employee could easily type the wrong recipient’s name, or a disgruntled worker could intentionally forward PHI to unauthorized parties.

Read more: Can you email PHI internally?

Best practices for HIPAA compliant internal emails

To ensure compliance with HIPAA, healthcare organizations can implement several best practices for internal email communications:

• Encryption: In December 2024, the HHS published a Notice of Proposed Rulemaking (NMPR), with proposed updates of the HIPAA Security Rule. These updates now mandate the implementation of encryption by HIPAA-regulated entities. This means that every email containing PHI should be encrypted, without requiring staff to take extra steps. Automatic encryption ensures messages are protected during transmission and storage. Without it, even a single misconfigured setting could expose PHI.
• Secure email servers: Standard email platforms like Gmail or Outlook are not automatically HIPAA compliant. Healthcare organizations need HIPAA compliant email servers that provide encryption, logging, and security controls. Solutions like Paubox Email Suite allow for seamless encryption without requiring portals or extra clicks, improving usability and compliance simultaneously.
• Access controls: The HIPAA Security Rule requires that “A regulated entity must implement technical policies and procedures for its electronic information systems that maintain ePHI to allow only authorized persons to access ePHI.” This requirement requires restricting email access to authorized individuals only. Implementing role-based access controls (RBAC) ensures that only those who need PHI for their work can access it.
• Training and awareness: HIPAA-regulated entities “must train all workforce members on its security policies and procedures.” This training must be conducted regularly and must train the workforce on the importance of securing internal communications. Employees should understand what constitutes PHI, how to handle it securely, and the consequences of non-compliance.
• Auditing and monitoring: Conduct regular audits of email communications to ensure that HIPAA standards are being followed. Monitoring tools can help detect and prevent unauthorized access to PHI. According to the HHS, these audits must be conducted “annually or as needed (e.g., bi-annual or every 3 years).

Go deeper: HIPAA compliant email best practices

The role of technology in compliance

Technology is both the problem and the solution in email compliance. While email remains a convenient communication tool, it introduces risks if not properly secured. Advanced HIPAA compliant platforms can bridge this gap.

The HIPAA

compliant solution: Paubox Email Suite

Paubox Email Suite is a comprehensive solution designed to make HIPAA compliance in internal communications seamless, secure, and practical for healthcare organizations. Unlike traditional secure email systems that rely on portals or manual encryption settings, Paubox provides automatic, always-on encryption for every email, ensuring that sensitive patient information is protected without requiring extra steps from staff. This layer of security reduces the risk of human error while allowing healthcare professionals to focus on patient care rather than technology. To further protect PHI, Paubox incorporates robust access controls, including role-based permissions, which align with HIPAA’s minimum necessary rule by ensuring only authorized personnel can send, receive, or view sensitive information. Equally important, the platform generates comprehensive audit trails that record email activity in detail, helping organizations demonstrate compliance during audits and investigations, and giving IT and compliance teams the visibility needed to identify and respond to unusual activity quickly. 

Unlike some secure email systems that disrupt workflows, Paubox is designed to integrate directly with familiar platforms like Microsoft 365 and Google Workspace, making adoption simple and user-friendly for employees at every level of the organization. In addition to securing internal communications between staff members, Paubox also ensures that external communications with patients, vendors, and business associates remain HIPAA compliant, allowing healthcare organizations to maintain a single, consistent standard of email security across all touchpoints. This dual capability reduces complexity, strengthens trust, and provides peace of mind that every message containing PHI is handled with the highest standards of confidentiality. 

Ultimately, Paubox Email Suite streamlines communication, enhances patient and staff experiences, and eliminates common barriers to compliance. By making HIPAA compliant email effortless, Paubox allows healthcare teams to spend less time worrying about security gaps and more time on what matters most—delivering safe, effective, and compassionate care to the patients who trust them.

Go deeper: Features of Paubox Email Suite

FAQs

Do all internal emails need to be HIPAA compliant, or only those with PHI?

Only emails that include PHI need to meet HIPAA compliance standards. However, best practices suggest using secure communication protocols for all internal emails to reduce the risk of accidental exposure.

Is using a personal email account for internal communication allowed?

No, using personal email accounts for internal communication involving PHI is not HIPAA compliant. Personal accounts lack the necessary security measures, such as encryption and audit trails, required under HIPAA.