HIPAA

In depth

HIPAA (Health Insurance Portability and Accountability Act, 1996) governs how covered entities — providers, plans, clearinghouses — and their business associates handle Protected Health Information (PHI). The Privacy Rule restricts disclosure; the Security Rule requires administrative, physical, and technical safeguards; the Breach Notification Rule mandates reporting. HIPAA does not directly regulate consumer-facing AI services like ChatGPT, but the moment a covered entity or business associate sends PHI to an AI service that has not signed a Business Associate Agreement (BAA), that transmission becomes a disclosure event the covered entity is responsible for.

Examples

  • A clinician pasting a patient's chart note into ChatGPT for summarisation — a disclosure event because OpenAI is not a BAA-covered partner.
  • A medical biller routing claim data through an unsanctioned AI tool to draft appeal letters.
  • A health-plan analyst using a personal Gemini account to forecast utilisation from member-level data.

How Locke handles hipaa

Locke detects patterns consistent with PHI — MRNs, ICD-10/CPT codes, NPIs, demographic combinations — locally, before any text reaches an AI tool. Because Sonomos itself never sees the data, no new BAA is required. See the Healthcare page for the full regulatory walk-through.

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