Why HIPAA applies to us

Aprendio isn't a clinic, but the moment we handle a client's patient data, federal law treats us as part of the healthcare system.

HIPAA protects health information held by covered entities: health care providers, health plans, and clearinghouses. An optometry practice, a medical billing company's provider clients, a spine surgeon's office: all covered entities.

When a covered entity lets a vendor handle its patients' information to do a job, that vendor is a business associate. When Aprendio builds a patient reminder workflow or cleans up a claims report, Aprendio is a business associate. And anyone Aprendio gives that information to is inside the same chain.

Where you sit in that chain

• Employees are part of Aprendio's workforce. You follow Aprendio's policies, and Aprendio answers for what you do.
• Contractors are subcontractor business associates. HIPAA requires you to sign a subcontractor BAA with Aprendio before you touch any patient data, and you are directly liable to the federal government for your own compliance, not only to Aprendio.

What's at stake

What counts as PHI

Protected health information is any information that relates to a person's health, their care, or payment for their care, and identifies them or could be used to identify them. Its form doesn't matter: a spreadsheet, a voicemail, a log line and a sticky note all count.

The 18 identifiers

Health information linked to any of these is PHI:

1. Names
2. Geographic data smaller than a state (street, city, ZIP)
3. Dates tied to a person (birth, admission, discharge, appointment, death) other than year
4. Phone numbers
5. Fax numbers
6. Email addresses
7. Social Security numbers
8. Medical record numbers
9. Health plan beneficiary numbers
10. Account numbers
11. Certificate or license numbers
12. Vehicle identifiers and plate numbers
13. Device identifiers and serial numbers
14. Web URLs
15. IP addresses
16. Biometric identifiers (fingerprints, voiceprints)
17. Full-face photos and comparable images
18. Any other unique identifying number, code, or characteristic

What PHI looks like in our work

It rarely looks like a medical chart. In Aprendio's work, PHI shows up as:

Even the fact that someone is a patient of a practice is PHI. A Slack message saying "Mrs. Alvarez called the Tampa office about her follow-up" contains PHI.

When it isn't PHI

Information that has been properly de-identified (all 18 identifiers removed, with no reasonable way to re-identify the person) is not PHI. Aggregate numbers like "412 appointments last month" aren't PHI either. But masking part of a name, dropping only the last name, or hashing an ID you can still look up is not de-identification.

Only what the job needs

HIPAA's minimum necessary standard means you use, share, and ask for the least PHI the task requires, and nothing for any other purpose.

In practice

• Build and test with synthetic data. Use real PHI only when the task can't be done without it, and only once Aprendio has confirmed you should.
• Pull the columns you need. A reminder workflow needs a name, phone number, and appointment time. It doesn't need diagnoses, insurance IDs, or the full chart.
• Don't browse. Never look up a patient out of curiosity: a neighbour, a public figure, someone you know. Access is logged, and "just looking" is a violation.
• Assigned work only. PHI is used only for the task Aprendio gave you. You may not keep it, reuse it for another client, or use it for anything of your own.

Things that are never allowed

Approved tools only, especially AI

Most of our work runs through AI models, automation platforms, databases, and logs. Each one copies data somewhere. Sending PHI to a tool that isn't approved is a disclosure, even when you meant well.

What makes a tool approved

A tool may hold PHI only if Aprendio has approved it in writing and at least one of these is true:

1. It is covered by a business associate agreement with Aprendio or the client, or
2. It runs under a zero-data-retention arrangement Aprendio has confirmed, or
3. It is self-hosted inside an environment Aprendio controls.

It must also run under an Aprendio or client account, never your personal account or personal API key. If a tool isn't on the approved list Aprendio gave you, it isn't approved. Ask before you use it.

The traps specific to our work

Coding agents

Claude Code, Cursor, Copilot and similar tools send what they read (files, query results, terminal output) to a model provider. If a repo, database, or log contains PHI, the agent is disclosing it. Point agents at synthetic data, or use them on PHI only under an Aprendio account that's approved for it.

Automation history

n8n saves the full input and output of every node in its execution history. A workflow that processes claims is quietly storing claims. Configure workflows so successful runs don't keep execution data, or prune it on the shortest schedule Aprendio approves, and never route PHI into an error notification that posts to Slack or email.

Logs and error tracking

Error trackers, analytics, and application logs often capture whole request bodies. Don't log PHI. Scrub fields before they're sent, and use only approved logging tools.

Source control

Never commit real exports, fixtures built from real data, or credentials that reach PHI. Git history is permanent and copied to every clone.

Securing your accounts and devices

These are Aprendio's minimum requirements (Schedule A of the subcontractor BAA) for anyone who can reach PHI. Use the checklist to check your own setup now.

Accounts

• Multi-factor authentication everywhere that can reach PHI or an Aprendio system, including the email you use for the work. Use an authenticator app, passkey, or hardware key. SMS is a last resort.
• Your own account, always. Never share log-ins, and never let someone else work under your account.
• Unique passwords in a password manager.
• Aprendio-controlled access. You reach PHI only through accounts Aprendio or the client issued, which Aprendio can switch off on the first day your access ends. Don't create your own API keys, forwarding rules, webhooks, or integrations that touch PHI without approval.

Devices

• Full-disk encryption on: FileVault on Mac, BitLocker on Windows. Modern phones encrypt when a passcode is set.
• Automatic security updates on, on a supported operating system.
• Screen lock of 5 minutes or less, plus a password or biometric log-in.
• Anti-malware and firewall on.
• Not shared with family members or anyone else.
• Listed with Aprendio. Tell Aprendio every device you use to reach PHI, and update the list within 5 business days when that changes.

Where PHI may live

Not on your device. Don't download, sync, or save PHI locally, on USB drives, or in personal cloud storage or email. If a task genuinely needs a temporary local copy, get Aprendio's approval first, keep it encrypted, and delete it (trash included) the same day.

Where you work

• Use a VPN or Aprendio-approved connection on public or shared Wi-Fi.
• Position your screen so others can't read it, and lock it whenever you step away.
• Don't access PHI from outside the United States without Aprendio's written approval naming the country. Many client agreements forbid offshore access.

Encryption, testing, and the coming Security Rule

In January 2025, HHS proposed the biggest update to the HIPAA Security Rule since it was written. Aprendio holds itself and its contractors to the proposed standard now, so the final rule doesn't catch us out.

What the proposal changes

Today many safeguards are "addressable", which lets an organisation document why it skipped them. The proposal makes nearly all of them mandatory, including:

What that means for you

• Keep your device list current so Aprendio's inventory and risk analysis are accurate.
• Don't run your own servers or databases with PHI. Aprendio's environment carries the scanning and pen testing. If Aprendio approves a system you operate, it takes on all of the obligations above.
• Certify every year. Contractors sign a yearly statement that they still meet the requirements, and Aprendio relies on it when it verifies its own safeguards to clients.
• Tell Aprendio within 24 hours when anyone working through you should lose access.

Incidents: tell Aprendio within 24 hours

Reporting quickly is always the right call. A late report does more damage than the original mistake.

What to report

Anything that might have exposed PHI or the accounts that reach it, even if you're not sure:

• PHI sent to the wrong person, or to a tool that isn't approved
• A lost or stolen laptop, phone, security key, or password
• Clicking a phishing link or entering your password on a fake page
• An MFA prompt you approved but didn't start
• A share link, bucket, or folder that was more open than it should have been
• Malware, ransomware, or odd behaviour on a device you work from
• Anyone accessing PHI they shouldn't, including someone working through you
• An outage or an emergency plan kicking in on a system that holds PHI

How to report

The 24 hours start at discovery: the moment you knew, or would have known if you'd been reasonably careful. Give what you know: what happened, when, what data and systems, who might have received it, and what you've done so far. Details can follow.

Why 24 hours?

A client practice has 60 days to notify patients after it learns of a breach, and less under some state laws (Florida allows 30). Many client agreements give Aprendio only a few days. Your 24 hours leave room for each link in the chain to do its part.

Phishing and pretexting

Attackers go after vendors because vendors often have access to several healthcare organisations at once. You're a target because of what you can reach.

What it looks like

• An email from a "client" asking you to send the patient list to a new address because "our office email is down"
• A shared document link that opens a Google or Microsoft log-in page
• A flood of MFA prompts late at night, hoping you'll tap "approve" to make them stop
• A message that seems to come from Michael asking you urgently to buy gift cards, change payment details, or grant someone access
• A "support" call asking you to read out a code that was just texted to you

The rules

1. Verify through a second channel you already know. Call the number you already have, or message the person on Slack. Never use the contact details in the suspicious message.
2. Never approve an MFA prompt you didn't start. Deny it and report it.
3. Never read out or forward a one-time code. Nobody legitimate asks for one.
4. Urgency is the tell. Real requests can wait five minutes for you to verify.
5. Report it, even if you didn't click. It helps Aprendio warn everyone else.

Outside requests and ending an assignment

If someone outside Aprendio asks for PHI

• A patient asks you for their records, a correction, or who has seen their data: forward it to Aprendio within 2 business days and don't reply. The client practice has legal deadlines for these requests, and they run through Aprendio.
• A subpoena, court order, or law enforcement request: tell Aprendio within 2 business days, before you disclose anything, unless the law forbids telling us.
• Anyone else, including a friendly vendor or another contractor: PHI goes only to the people Aprendio has approved.

Anyone working through you

If you're a contractor with your own staff or helpers, only people Aprendio has approved by name may touch PHI, and each must complete this training. You may not use your own subcontractors for PHI work without Aprendio's written approval and a BAA between you and them. You're responsible for everyone who works through you.

When an assignment ends

Access is switched off on the first day your assignment ends. Within 5 business days you:

1. Sign out of and hand back every Aprendio and client account, credential, token, and device.
2. Delete all PHI everywhere it may have ended up: Downloads, Desktop, trash, email, cloud drives, chat histories, AI tool histories, recordings.
3. Confirm in writing to Aprendio that you've done it.

Every year

Retake this training every 12 months, and whenever Aprendio asks after a change in law or an incident. Contractors also sign a yearly statement that they still meet the security requirements.

Final exam

22 scenario questions. You need 80% (18 correct) to pass. The questions and answers are shuffled on each attempt, and you can retake the exam as often as you need.

Acknowledgement

Check each statement to confirm it, then type your name to sign.

You passed. Here's your certificate.

Save it as a PDF: choose Print, then Save as PDF as the destination.

Certificate ID

Completed

Exam score

What happens next

1. Save the certificate as a PDF and send it to michael@aprendio.ai. The email button above fills in your completion record; attach the PDF before you send.
2. Contractors: Aprendio will send you the Subcontractor Business Associate Agreement through sign.aprendio.ai. Enter the certificate ID and completion date shown above when you sign it.
3. Don't access any PHI until Aprendio confirms your agreement is signed and your accounts are set up.
4. Your training expires in 12 months. You'll need to retake it before then.

Aprendio can check a certificate at the verification page.

Verify a certificate

Enter the details exactly as they appear on the certificate and in the completion email.