Earlier this year, Health Department officials in Multnomah County, Oregon discovered an employee set up an automatic mail forwarder that resulted in a HIPAA violation. The employee in question configured their work email account to automatically forward all email to a personal Gmail account.
As we’ve previously covered, when it comes to Gmail and HIPAA compliance, the two don’t mix. In a nutshell, Google is willing to sign a Business Associate Agreement (BAA) for use with some, but not all, of their services.
Google does not offer a BAA for Gmail.com accounts.
SEE RELATED: How to Make Gmail HIPAA Compliant
The employee who committed the HIPAA violation works in the Multnomah County Health Department. That means emails sent to that person’s work email were automatically forwarding the following protected health information (PHI):
- Medical record numbers
- Medical diagnoses
- Dates of service
- Medication names
- Prescription numbers
The HIPAA violation was found during a random audit in November 2016. A subsequent internal investigation found that:
- The email forwarding occurred for over four years (Aug 2012 – Nov 2016).
- PHI for about 1700 patients was exposed.
- There was no evidence that the forwarded emails were read, forwarded or sold to another party.
- Social Security numbers, home addresses, or phone numbers were not present in the forwarded emails.
Although the County confirmed that the gmail account had deleted, the possibility that PHI was inappropriately accessed could not be ruled out.
Why Would an Employee Forward PHI to Their Personal Account?
It is unclear why the emails were forwarded to the employee’s gmail account. Although it may have been an innocent mistake, it still represents a HIPAA violation.
How Can Paubox Suite Premium Help?
In the case of Multnomah County, a good email DLP solution would have detected when that employee included things like Medical record numbers, Medication names and Medical diagnoses to a personal account.
In the case of Paubox Suite Premium, we would:
- Quarantine the outbound email.
- Send an email alert to the DLP administrator.
- Optionally send an email alert to the sender notifying them their email got quarantined.