Cloud-based file-sharing apps have become an integral part of work, particularly with the rise of remote workers. They are a secure and convenient way to share content with colleagues and even external parties.
One such popular tool is Dropbox. It comes with many convenient features like AI-powered search, smart organization, and natural integration with many apps. It is also known for security capabilities, like encryption and access controls, making it a good choice for organizations that want to balance between ease of use and security.
That said, some compliance standards require high levels of security, especially for organizations that deal with sensitive data. A case in point is the Health Insurance Portability and Accountability Act (HIPAA) in the U.S. This is a federal law enacted in 1996 to protect the sensitive health information of patients, and it applies to any healthcare organization that deals with this kind of data. Under this Act, the organization is responsible for ensuring the safety of its patient data, regardless of which software tools are used for operations.
Is Dropbox HIPAA-compliant?
Read on, as we explore the different features of Dropbox and map them against HIPAA rules to evaluate if Dropbox is a good option for organizations that must meet HIPAA guidelines.
Understanding HIPAA
Before we dive into whether Dropbox meets HIPAA’s rules, let’s take a step back to understand what HIPAA is in the first place.
HIPAA is a federal legislation enacted in 1996 to establish the standards for protecting sensitive patient information. It is enforced by the U.S. Department of Health and Human Services (HHS) through the Office of Civil Rights (OCR), with the latter being responsible for investigating complaints and conducting compliance audits.
With the emergence of technology, HIPAA’s coverage also extends to electronic Personally Identifiable Information (ePHI). As the name suggests, this information can be used to identify a specific individual, and can include information like name, address, Social Security Number, phone number, email ID, and more. This PII, whether in physical or electronic format, must be protected from unauthorized access.
Who Must Comply?
Which companies are responsible for safeguarding PII? HIPAA puts this responsibility on two categories of organizations.
Covered Entities
Covered entities are organizations that directly offer healthcare or healthcare-related services, and include:
- Healthcare providers like doctors, nurses, dentists, chiropractors, psychologists, and anyone who will handle patient health data.
- Organizations offering health plans like insurance companies, HMOs, and government providers like Medicare and Medicaid.
- Clearing houses that are responsible for standardizing patient health data.
Business Associates
Business Associates (BAs) are those entities that perform certain activities on behalf of the covered entities described above. These activities can include IT support, cloud storage providers like Dropbox, billing companies, accounting firms, etc. These entities may also have access to PII. The key aspect is that the covered entities will be responsible for the actions of the BAs, and this is why it’s important for both parties to enter into a Business Associate Agreement (BAA), which lays down the responsibilities on each party for safeguarding PHI.
HIPAA’s Core Rules
There are two main HIPAA rules that are relevant to understanding if Dropbox can keep you compliant. These two rules are the Security Rule and the Privacy Rule.
Security Rule
This rule is the one responsible for protecting the safety of ePHI. It requires BAs and covered entities to implement physical, technical, and administrative controls, like the following:
- Access controls that limit who can access ePHI.
- Audit controls to track access and activities.
- Detect unauthorized changes to information.
- Encryption during storage and transmission.
The idea of these measures is to ensure the integrity and availability of ePHI at all times.
Privacy Rule
The Privacy Rule, on the other hand, is more about how the data is accessed and by whom. Primarily, it focuses on getting the patient’s consent before the data is shared to another entity. Also, it revolves around the rights of patients to examine their data, request corrections, and obtain a copy of their records.
These two rules and the way they are implemented by covered entities and BAs determine the level of HIPAA compliance.
Violations of these rules can result in fines ranging from $100 to $50,000, with a maximum of $1.5 million.
Now, let’s compare Dropbox’s features against these rules to understand if it is HIPAA-compliant.
Is Dropbox HIPAA-compliant?
Dropbox is one of the most popular and widely used file storage and collaboration platforms in the world. However, it is not HIPAA-compliant by default. This means you must take additional steps to make this tool HIPAA-compliant. Without these measures in place, you cannot use Dropbox for storing, transmitting, or managing ePHI.
Specifically, you must:
- Subscribe to Dropbox’s Business, Business Plus, or Enterprise plan.
- Sign a BAA with Dropbox.
- Configure the settings for HIPAA compliance.
Note that the individual and free plans are not eligible for HIPAA compliance. Only Business plans and above offer features like AES-256 encryption, advanced sharing permissions, audit logs, remote data wiping, role-based access controls, and more. All these features can help meet HIPAA’s security and privacy rules.
Dropbox Features that Support HIPAA Compliance
When you meet the above-mentioned criteria, you will have access to Dropbox’s premium features that align with HIPAA requirements. These features are:
Encryption
Though HIPAA does not explicitly require the implementation of encryption, it mandates the protection of data during storage and transit. Drop meets this requirement with its strong encryption protocols, like AES-256 for encrypting the files at rest. While transmitting them, Dropbox uses SSL/TLS encryption protocols to prevent unauthorized access to the data.
Access Controls
HIPAA requires that organizations allow only authorized users to access the ePHI of patients. To achieve this requirement, Dropbox offers,
- Role-based access permissions.
- Password-protected links for safe sharing.
- Creation of user roles with custom privileges.
- Single Sign-On (SSO) integration.
Audit Requirements
As per HIPAA’s Security Rule, you must log all access to ePHI and monitor it regularly to ensure that ePHI is not misused or stolen. The following Dropbox features come in handy to meet this rule.
- Creates audit logs for file access, sharing, and modifications.
- Sends alerts for suspicious behavior.
- Integrates well with other SIEM tools for monitoring.
- Generates audit trails and reports to prove compliance during audits.
Device and Session Management
Additionally, Dropbox offers in-depth features for device and session management to meet HIPAA’s rules. Using these features, admins can:
- View all the devices linked to an account.
- Remotely log out devices from sessions.
- Remotely wipe data from lost and stolen devices.
These device and session management features add another layer of protection if an authorized device ever gets lost or stolen.
Two-factor Authentication (2FA)
To further protect data from unauthorized access, you can implement 2FA, where users have to sign up for a secondary authentication mechanism, like a code via SMS or an authenticator app. Only when this secondary code is entered can users access ePHI. This adds an extra layer of protection.
All these features ensure that the advanced plans of Dropbox help you meet the requirements of HIPAA.
Limitations of Dropbox for HIPAA Compliance
Despite the above features, there are still some limitations when you use Dropbox in a HIPAA context. Some aspects to watch out for are:
No Native DLP
Dropbox does not offer built-in Data Loss Prevention (DLP) for ePHI. What this means is that you can’t detect or restrict the sharing of sensitive data without integrating with third-party tools.
Manual Configurations
Another limitation is that you must include the necessary configurations to make Dropbox HIPAA-compliant. For example, admins must manually implement 2FA for all users, configure role-based permissions, and explicitly limit sharing. These manual configurations increase administrative overhead. More importantly, if these settings are misconfigured, it can lead to non-compliance.
Clinical Communication
Dropbox is not particularly designed for clinical communication, as it does not come with secure messaging or patient communication portals. In other words, Dropbox is just a document management and collaboration tool and cannot be used for other activities.
You can overcome the above limitations with the following measures.
- Before deploying Dropbox, do a detailed HIPAA risk assessment to identify the gaps, so you can fix them with configurations or third-party apps.
- Train all employees on HIPAA regulations and how to use Dropbox to fulfill these requirements.
- Use third-party tools where needed, to overcome the gaps.
- Regularly review the audit logs for unauthorized access attempts.
- Create and maintain an incident response plan that can be activated to mitigate security incidents.
With such measures, you can make Dropbox compliant with HIPAA.
Final Verdict – Is Dropbox HIPAA-compliant?
In short, yes, but with certain changes. You must opt for the Business plan or higher, sign a BAA, train your staff, and make manual configuration changes. Even small missteps can lead to non-compliance, and this is why it’s a good idea for large organizations to opt for tools like M365 or Google Workspace, as they offer more comprehensive features.
At the same time, Dropbox is a good choice for small and medium organizations with strong internal controls, provided they need only a secure file storage and sharing tool. Even then, configurations and BAA are mandatory.