The Challenge
The dilemma hinged on differing perspectives from legal and marketing. The legal team aimed to minimize compliance risks, whereas the marketing team insisted that eliminating Google Analytics would undermine a crucial component of their digital strategy.
The Solution
Penrod sought to balance risk with the marketing team’s reliance on Google Analytics for behavior analysis, experience enhancement, and results measurement. Penrod's solution contains three key components: a secure server-side container for data processing, a data redaction engine – and a customer data platform (CDP) based on the OCR’s recent statements recommending CDPs for compliance.
1. Server Side Container
First, our client needed a secure environment to process, redact, and control PHI. Penrod leveraged Amazon Web Services (AWS) based on two key criteria: AWS signs BAAs, and it seamlessly integrates with Google Tag Manager.
2. Data Redaction Engine
Penrod's HIPAA-compliant web tracking solution uses a redaction engine based on opt-in logic. By default, the system prevents the transmission of PHI to Google Analytics and anonymizes identifiers like IP addresses or device IDs using a secure hashing algorithm.
Additionally, the solution can redact any default or custom parameter, giving our client complete control over its website visitors’ privacy.
3. Customer Data Platform
Our client's marketing team was concerned that the OCR bulletin would hinder their ability to track campaign performance with historical data. Penrod alleviated these concerns by integrating Salesforce Data Cloud, a cutting-edge customer data platform (CDP) that could store every data point they needed.
Unified Web Visitor Profiles
After signing a BAA with Data Cloud, our client could send un-redacted visitor data into the platform. As a result, all visitor information is now stored in a HIPAA-compliant CDP – and is ready for deep analysis. Utilizing a universal identifier, hashed data in Google Analytics can be re-identified within the CDP.
Salesforce Data Cloud will empower our client to create robust unified profiles by ingesting data from other systems, including EHRs, ERPs, and marketing automation platforms.
Friendly Configuration Interface
Data Cloud functions as a configuration engine for the opt-in redaction system. With an intuitive user interface, our client’s users can easily choose which parameters are safe for Google Analytics and which should be redacted, hashed, or removed. This approach ensures the solution remains adaptable to any future updates or guidelines issued by the OCR regarding third-party trackers.
The Results
Completing the Journey to OCR Compliance
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