Twilio is a cloud communications platform that allows developers to integrate different communication methods, like voice, messaging, and video, into their applications using APIs (Application Programming Interfaces).
Twilio's services are widely used by businesses for tasks like sending text messages, handling customer support calls, allowing medical providers to extend their telehealth services.
Is Twilio HIPAA compliant?
Yes, based on our research, some Twilio products can be HIPAA compliant.
Will Twilio sign a business associate agreement (BAA)?
Yes, Twilio does offer a BAA for covered entities for some of its products. Customers that are subject to HIPAA and intend to utilize Twilio to develop communication workflows containing PHI must execute what it calls a "business associate addendum" (i.e., a BAA) to Twilio’s Terms of Service. The company explains its BAA more closely here.
What products does the Twilio BAA cover?
Only certain Twilio products and services are eligible for HIPAA compliance, like their programmable SMS, video, voice and SIP as well as runtime tools.
Twilio explains: "Twilio’s BAA has been developed taking into account the specific products and services that Twilio offers and considers HIPAA compliance as a shared responsibility between the customer and Twilio."
Their BAA covers:
US State Privacy Laws, including but not limited to the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act.
For personal data subject to the CCPA:
- Twilio acts as a service provider when processing Customer Content.
- Twilio will process personal information contained in Customer Content only for the business purposes set forth in the Agreement.
- Customers have rights to ensure Twilio's consistent use of personal information.
- Twilio provides assistance and notifies customers of any inability to meet CCPA obligations.
- Twilio certifies understanding and compliance with CCPA obligations.
Conclusion
Some Twilio products may be HIPAA compliant, but the company sees HIPAA compliance as a shared responsibility. So, to achieve compliance, customers will need Enterprise Edition, sign a BAA, and follow Twilio's HIPAA requirements and recommendations.
Learn more: HIPAA Compliant Email: The Definitive Guide
FAQs
What is a business associate agreement?
A business associate agreement (BAA) is a legally binding contract establishing a relationship between a covered entity under the Health Insurance Portability and Accountability Act (HIPAA) and its business associates. The purpose of this agreement is to ensure the proper protection of personal health information (PHI) as required by HIPAA regulations.
What is HIPAA?
The Health Insurance Portability and Accountability Act (HIPAA) sets national standards for protecting the privacy and security of certain health information, known as protected health information (PHI).
HIPAA is designed to protect the privacy and security of individuals’ health information and to ensure that healthcare providers and insurers can securely exchange electronic health information. Violations of HIPAA can result in significant fines and penalties for covered entities.
Who does HIPAA apply to?
HIPAA applies to covered entities, which include healthcare providers, health plans, and healthcare clearinghouses. It also applies to business associates of these covered entities. These are entities that perform certain functions or activities on behalf of the covered entity.
