Freshpaint provides several features to restrict and manage Protected Health Information (PHI) in your customer data.
HIPAA mode is a feature that Freshpaint provides to give customers full control over what Protected Health Information (PHI) is sent to their destinations. Freshpaint allows you to configure explicit lists of properties, called allowlists, for each of your destinations so you opt into what you send and how you send it.
PHI is the combination of Personal Identifiable Information (PII) and health information. Examples of PII include:
- IP Addresses
- Non-anonymized user IDs
Examples of health information include:
- Treatment information
- Medical test results
- Prescription information
The Enforced Allowlists feature allows you to send properties classified as PHI to your HIPAA-compliant destinations, and send only non-PHI properties to non-HIPAA compliant destinations. Freshpaint does this by allowing you to specify a list of properties that are known to not contain PHI. Whenever Freshpaint sees an event or user property that is not in this allowlist, Freshpaint will remove the property before sending the event or identify request to non-HIPAA compliant destinations.
Add non-PHI properties to a project's allowlists to send them to non-HIPAA compliant destinations
ID Masking allows you to identify users in Freshpaint using a non-anonymized ID without sending the identifier to non-HIPAA compliant destinations. Freshpaint does this by hashing the user identifier before sending events to non-HIPAA compliant destinations. This anonymizes the user identifier, while still associating events with a single identified user and preserving functionality like identity resolution.
Here's an example. Suppose you identified a user by their email address:
Masking would send values like
[email protected]in a hashed form, scrambled in such a way that a reader at the destination will be unable to determine the original value. This hashing is consistent for a given value. If
[email protected]is hashed into
iuUwhqIm1kEriZsVlu5TsGgX6/y5Pwfn, then you can count on it being that value every time in your destinations.
To turn on ID Masking, you must configure the allowlist for your destination. Add the property you want to allow, then check the
Freshpaint's HIPAA mode requires your destinations be configured with a server-side connection. If one of your destinations only supports a client-side connection, you will not be able to use them in HIPAA mode.
You may want to send events to a non-HIPAA compliant destination without applying ID Masking or Allowlists. This might be the case when:
- You want to send events to a non-HIPAA compliant destination that only supports Client-side connection mode, so you need to disable HIPAA mode to use the client-side destination.
- You want to send events to a non-HIPAA compliant destination, and the destination needs the original user identifier, so you need to disable ID masking.
To avoid sending PHI to a non-HIPAA compliant destination, you must restrict PII, health information, or both. Note that this restriction is scoped to all API calls made for a user. For example:
- You attach PII (but not health information) to an anonymous user in a destination with a
- Later on, you send a
Freshpaint.track()API call containing health information (but not PII) to the same destination for this anonymous user
You're still sending PHI to the destination, since the destination has received both PII and health information for the same user, even though this information was received in different requests.
When determining whether a destination may collect PHI, it's important to understand exactly what metadata and properties a destination collects, and whether these metadata and properties contain PII or health information.
For example, the Freshpaint Bing Ads destination collects IP addresses, Freshpaint event names, and page URLs (alongside other metadata). Because an IP address is PII, it's important to ensure the event names and page URLs collected by Bing Ads do not include health information.
And of course, you should always consult with your legal team.