In December, the U.S. Department of Health and Human Services (HHS) issued a Bulletin about changes to the Health Insurance Portability and Accountability Act around the “Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates.”
Throughout the month of December, Schema App partnered with our Healthcare clients to identify how these new requirements impact their schema markup and how Schema App can help.
What are the requirements?
The new Bulletin defines additional requirements for “tracking technology vendors” who are tracking individually identifiable health information (IIHI), such as medical record numbers, home or email addresses or individual IP addresses.
“Regulated entities disclose a variety of information to tracking technology vendors through tracking technologies placed on a regulated entity’s website or mobile app, including individually identifiable health information (IIHI)19 that the individual provides when they use regulated entities’ websites or mobile apps. This information might include an individual’s medical record number, home or email address, or dates of appointments, as well as an individual’s IP address or geographic location, medical device IDs, or any unique identifying code.20 “
How does this apply to Schema Markup?
Schema Markup is code on your website that helps search engines understand the content on your website. Search engines like Google crawl a website, read the code and reward the page by displaying it as a rich result on the search engine results page.
Many healthcare organizations use Schema Markup to achieve rich results and stand out in search. At Schema App, we help health networks add the Schema Markup to their website.
Example of a Review Snippet Rich Result awarded to a healthcare organization.
How does this HIPAA change apply to Schema App?
Schema App is an end-to-end Schema Markup solution provider that integrates with your website to create, manage and deploy your Schema Markup at scale.
The only data point that Schema App uses to deliver the service listed in the IIHI is the IP Address. However, Schema App does not store this individually identifiable information.
Why do we use IP Addresses?
All web browsers include the user’s IP address to request web resources, such as an image, JSON-LD or Javascript, so that those resources can be delivered to the requester and rendered as a website. This is how web pages the user requests are routed back to the client user.
Schema App is a web resource, and therefore requires the user’s IP address to deliver the JSON-LD to the browser.
Once the JSON-LD is delivered to the web browser, Schema App anonymizes the IP addresses and stores the anonymized IP Address for 30 days for troubleshooting purposes. These anonymized IP Addresses are stored in our cloud provider (AWS) and are only accessible by administrators.
Since the IP Address is anonymized, no IIHI is stored by Schema App. For more information, please refer to our privacy policy.
Approaches our Healthcare clients are taking to navigate these HIPAA changes
Our clients are using various approaches to comply with this new HIPAA requirement.
- Reducing the number of tags in Google Tag Manager and/or moving to manage Javascript on their CMS/Webpages directly. You can learn how our Javascript Integration works in detail here.
- Asking Schema App to sign a Business Associate Agreement. If this is required for you, Schema App will review your BAA.
- Considering vendor server side / CMS integrations. At Schema App, we have custom integrations with Adobe Experience Manager, Drupal, WordPress, Shopify, and BigCommerce. If yours is not listed, contact us for a suitable integration solution.
Conclusion
In conclusion, Schema App does not store any IIHI information in our database and is therefore compliant with HIPAA’s new rules.
Our team at Schema App is actively helping our healthcare clients navigate these changes. If your organization is currently deploying Schema Markup through Google Tag Manager with Schema App, please reach out to your Customer Success Manager to explore alternative integration methods.
If your healthcare organization is looking to leverage Schema Markup to bolster your digital marketing efforts, we can help. Get in touch with us to learn how we can help your organization stay ahead of the competition and stand out in search.
Ready to leverage Schema Markup to drive traffic to your site?
Martha is the CEO and co-founder of Schema App. Schema App is an end-to-end Schema Markup solution that helps enterprise SEO teams create, deploy and manage Schema Markup to stand out in search. She is an active member of the search engine optimization community, and the work that she does through Schema App is helping brands from all over the world improve their organic search performance.
