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Is Google Sheets HIPAA Compliant?

Google Sheets is HIPAA compliant and can be used to create, manage, and share spreadsheets containing Protected Health Information (PHI) provided organizations subscribe to a Google Workspace plan that supports HIPAA compliance and Google Drive is configured to control access to files saved as Google Sheets. In addition, system administrators are required to review and accept Google’s Business Associate Addendum to the Workspace Service Agreement.

Under HIPAA Rules, healthcare organizations are required to implement safeguards to ensure the confidentiality, integrity, and availability of PHI. While it is straightforward to implement controls internally to keep data secure, oftentimes third parties are contracted to provide services that require access to PHI. They too must abide by HIPAA Rules covering privacy, security, and breach notifications.

A third-party that requires access to PHI – or copies of health data – to perform services on behalf of a covered entity is considered a business associate. A covered entity and business associate must enter into a contract – a business associate agreement – in which the business associate agrees to comply with certain aspects of the HIPAA Privacy, Security, and Breach Notification Rules. Without a business associate agreement in place, any sharing of PHI would be considered a HIPAA violation.

Google does not look at the information uploaded to Google Sheets, but has “persistent access” to data is stored on its servers, so a business associate agreement is required.

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Will Google Sign a BAA with HIPAA Covered Entities?

Google is committed to protecting the privacy of its customers’ data and ensuring all of its services are secure and data can always be accessed. Google is aware of the requirements of the Health Insurance Portability and Accountability Act and is prepared to enter into a business associate agreement with HIPAA covered entities for certain services in the Workspace suite of productivity tools.

However, rather than agreeing to the terms of each individual customer’s Business Associate Agreement, Google offers a one-size-fits-all Business Associate Addendum to the Workspace Service Agreement which covers productivity tools such as Google Drive. Google Sheets, Google Docs, Google Slides, and Google Forms.

To help organizations configure the productivity tools in compliance with HIPAA, Google also offers a HIPAA Implementation Guide for services with “covered functionality”.

Is Google Sheets HIPAA Compliant?

Since Google offers a BAA, is Google Sheets HIPAA compliant? Google can be considered a HIPAA compliant service provider as Google supports HIPAA compliance for most business Workspace accounts. Once a BAA has been obtained, it is the responsibility of the covered entity or business associate to ensure that Google Sheets and all other Google Drive and Workspace products and services are used correctly in a manner that does not violate HIPAA Rules.

Author: Steve Alder is the editor-in-chief of HIPAA Journal. Steve is responsible for editorial policy regarding the topics covered in The HIPAA Journal. He is a specialist on healthcare industry legal and regulatory affairs, and has 10 years of experience writing about HIPAA and other related legal topics. Steve has developed a deep understanding of regulatory issues surrounding the use of information technology in the healthcare industry and has written hundreds of articles on HIPAA-related topics. Steve shapes the editorial policy of The HIPAA Journal, ensuring its comprehensive coverage of critical topics. Steve Alder is considered an authority in the healthcare industry on HIPAA. The HIPAA Journal has evolved into the leading independent authority on HIPAA under Steve’s editorial leadership. Steve manages a team of writers and is responsible for the factual and legal accuracy of all content published on The HIPAA Journal. Steve holds a Bachelor’s of Science degree from the University of Liverpool. You can connect with Steve via LinkedIn or email via stevealder(at)hipaajournal.com

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