Privacy Examiner’s mission is to help healthcare organizations identify, understand, and reduce website-level HIPAA exposure risk using evidence-based detection and disciplined, regulator-aligned analysis. We exist to make invisible website risk visible, explainable, and fixable, without overstating conclusions or providing legal determinations. Our focus is patient privacy protection through practical risk reduction, documentation, and ongoing monitoring rather than fear-based selling or compliance theater.
Privacy Examiner exists because website privacy has become a persistent blind spot in healthcare compliance. Most healthcare websites were built or managed by marketing and web vendors using standard tools that were never designed for HIPAA-regulated environments. As regulatory guidance around online tracking technologies has evolved, many practices now carry exposure they did not knowingly create and do not know how to assess. Privacy Examiner fills this gap by operating as an independent examiner focused specifically on website risk.
We are designed to solve one specific problem: healthcare organizations often lack independent, technically grounded visibility into what their public websites are actually sharing with third parties. Traditional HIPAA programs focus on clinical systems, policies, and training, while marketing vendors focus on performance. Privacy Examiner addresses the intersection where those worlds collide, website technologies that quietly create HIPAA exposure.
Privacy Examiner is intentionally not a marketing agency and not a general compliance consultancy. We do not sell advertising, performance optimization, or website redesign as our core offering. Our incentives are aligned around risk reduction first, while recognizing that healthcare organizations still need effective, sustainable marketing. Our role is to help practices reduce privacy exposure without unnecessarily harming patient access, visibility, or legitimate growth efforts. We focus on externally observable evidence, vendor posture, and architectural risk patterns so our findings can withstand scrutiny from legal, compliance, and technical stakeholders.
Privacy Examiner is an independent HIPAA website risk detection and monitoring company focused on healthcare websites. We examine publicly observable website technologies and configurations to identify risk surfaces that may create HIPAA exposure in a healthcare context. We document what we detect, explain why it may matter, and help practices understand remediation options and ongoing monitoring.
Privacy Examiner does not provide legal advice, certify HIPAA compliance, guarantee outcomes, or act as a regulator. We do not submit forms, access patient portals, or collect PHI during reviews. Our role is limited to detection, explanation, remediation support, and monitoring, allowing practices and their advisors to make informed decisions.
No. Privacy Examiner does not provide insurance, indemnity, or financial coverage against HIPAA claims, investigations, or liabilities related to a practice’s website. Our work is designed to reduce risk by identifying externally observable risk surfaces, supporting remediation, and documenting ongoing monitoring, but it cannot eliminate all risk and should not be treated as a substitute for legal counsel or insurance coverage. If your organization wants coverage for privacy or cyber-related events, that is typically handled through specialty insurance products and should be discussed with your insurance broker and legal advisors. Legal interpretation, compliance determinations, and enforcement decisions remain the responsibility of the practice and its legal counsel.
No. Privacy Examiner does not perform comprehensive HIPAA compliance audits or issue certifications. Our services are purpose-built to address website-level risk surfaces, which are often overlooked in traditional compliance programs. We focus on externally detectable technologies, vendor posture, and architectural risk patterns that regulators have highlighted, while avoiding legal conclusions or representations that exceed our role.
No. A notification does not assert a confirmed HIPAA violation. It indicates that our limited, non-invasive review detected one or more technologies or configurations that may create HIPAA exposure risk in a healthcare context. Determining compliance status requires a fuller, fact-specific review.
Our reviews rely on externally observable evidence only. We analyze page source, scripts, network requests, headers, and publicly reachable pages. We do not submit forms, access portals, or collect patient information.
We look for categories of technologies commonly associated with website-level HIPAA exposure, including analytics scripts, advertising and conversion tracking, session replay tools, chat widgets, third-party forms or scheduling embeds, hosting environments, and certain embedded third-party content. Findings are contextual and depend on where and how tools are used.
HIPAA generally requires a Business Associate Agreement when a vendor creates, receives, maintains, or transmits PHI on behalf of a covered entity. When a vendor does not offer or will not execute a BAA for the specific product in use, certain website configurations may create unavoidable third-party exposure in a healthcare context. Under Privacy Examiner’s internal risk standards, remediation in these situations typically involves removal, replacement, or strict isolation rather than policy-based mitigation.
No. Privacy policies and cookie banners do not, by themselves, authorize the disclosure of PHI to third parties. If a technology creates a third-party disclosure pathway in a healthcare context and the vendor does not support HIPAA-aligned safeguards, policy language alone does not resolve the underlying risk surface.
If you choose, we can coordinate with your existing vendors during remediation. Our role is independent. We document what is present and help your team or vendors remove or isolate risk appropriately.
This is one of the most common situations we encounter. Many marketing agencies and web vendors operate using standard industry tools and configurations that are widely accepted in non-regulated industries. Those same configurations may create HIPAA exposure risk in a healthcare context, even when implemented correctly from a marketing perspective.
Marketing vendors typically assess success based on performance, attribution, and conversion tracking. They are rarely tasked with evaluating whether third-party tools create disclosure pathways that are acceptable under HIPAA or whether a vendor will execute a Business Associate Agreement for the specific product in use.
Privacy Examiner’s role is different. We do not evaluate marketing effectiveness. We evaluate whether publicly observable website technologies may create third-party access to healthcare-related user activity that cannot be reliably constrained. A vendor stating that a setup is “fine” often means it is functioning as designed, not that it has been assessed against HIPAA-aligned risk standards.
General HIPAA awareness is not the same as HIPAA-aligned operation at the website level. Many vendors use the term loosely to describe internal training, good intentions, or experience working with healthcare clients.
What matters operationally is whether the specific technologies deployed on your website can be used in a healthcare context without creating third-party disclosure risk, and whether the vendors involved support HIPAA safeguards contractually and technically. In many cases, tools that are common in healthcare marketing are not offered under BAAs or are not designed to operate safely on patient-action pages.
Privacy Examiner focuses on what is actually loading on your site, where it appears, and what the underlying vendor posture is, rather than relying on generalized assurances.
Yes. Website-level HIPAA exposure is extremely common across healthcare organizations of all sizes. Most medical websites were built or managed using standard marketing, analytics, and engagement tools that were not designed for regulated environments. In many cases, these configurations were implemented years ago and persisted without review. The resulting risk is usually unintentional, which is precisely why independent examination is necessary.
Some findings are contextual and depend on how a tool is used. Others involve architectural risk where third-party access is inherent by design.
Privacy Examiner distinguishes between informational, contextual, and high-confidence architectural risk surfaces. When a finding is classified as architectural under our internal standards, it means the exposure pathway cannot be reliably eliminated through configuration alone. That is an operational concern regardless of whether enforcement has occurred.
Most practices have not experienced enforcement or complaints related to website technologies. That does not mean risk is absent. Website risk is often invisible to patients and administrators until it is examined directly.
Addressing these issues proactively allows practices to reduce uncertainty, document due diligence, and avoid reactive remediation under time pressure.
Choosing not to address website-level privacy risk is an operational decision. While some practices decide to defer remediation, it is important to understand the potential consequences of leaving known risk surfaces in place.
Regulatory expectations related to online tracking technologies have become clearer over time, and enforcement attention has increased. Practices that do not review or address known risk surfaces may also lack documentation demonstrating reasonable due diligence if questions arise later.
In addition, vendor-driven changes can quietly increase exposure over time, and addressing issues reactively often leads to rushed remediation, higher cost, and operational disruption. Privacy Examiner does not assert that inaction guarantees enforcement or penalties, but unexamined configurations can compound risk and reduce flexibility.
HHS, through its Office for Civil Rights (OCR), has authority to investigate HIPAA Privacy Rule and Security Rule issues and to impose civil money penalties or settlement agreements. OCR guidance explicitly warns that noncompliance with the HIPAA Rules may result in civil money penalties and states that OCR is prioritizing Security Rule compliance in investigations involving online tracking technologies.
At the same time, enforcement in this area is evolving. While publicly announced OCR cases have historically focused more on areas like ransomware or access-to-records, website tracking risk often surfaces through complaints, investigations, litigation, and reputational harm rather than a single fine.
Privacy Examiner does not predict enforcement outcomes or provide legal conclusions. Our role is to help you understand operational risk and options for reducing exposure.
Not always. Many remediation actions are targeted and limited in scope, such as removing a specific tracking script, isolating patient-action pages, or adjusting how certain tools load. These changes can often be implemented quickly once the underlying issue is identified. More complex remediation, such as hosting changes or workflow redesign, does occur but is far less disruptive when addressed proactively rather than under time pressure.
Removing certain advertising, conversion, or behavioral tracking tools may change how marketing performance is measured, but it does not prevent a practice from growing or attracting patients. Many healthcare organizations successfully adopt HIPAA-aligned growth strategies that emphasize content quality, local visibility, reputation management, and compliant analytics. In practice, remediation often shifts measurement approaches rather than eliminating marketing effectiveness.
Most practices schedule a confidential discovery call. During that call, we review what was detected, explain why it may matter, and outline options. Practices can then decide whether to proceed with a comprehensive scan, remediation consulting, or ongoing monitoring.
The next step is typically a confidential discussion to review the detected items and your options. From there, you can determine the appropriate scope and timing of remediation or monitoring.
HIPAA obligations apply regardless of practice size. Smaller practices and independent providers are subject to the same Privacy Rule and Security Rule standards as large health systems. In practice, smaller organizations often rely more heavily on third-party vendors and off-the-shelf tools, which can increase website-level risk even when patient volume is lower. Size does not reduce regulatory responsibility, and smaller practices may feel the operational impact of remediation or investigation more acutely.
Yes. Even basic contact forms can create healthcare context depending on how they are used, what information they request, and what technologies load on the same page. When a website represents a medical practice, a visitor submitting a contact form is often expressing care-seeking intent, even if the form itself appears simple. If third-party scripts, analytics, or marketing tools are present on that page, they may observe page context or interaction events that imply healthcare activity. Risk assessment depends on the combination of form purpose, page content, and the surrounding technical environment, not solely on whether the form is labeled “contact” or “appointment.”
HIPAA risk is not limited to whether information is stored in a database. Exposure can arise from transmission, access, or inference of healthcare-related activity even when data is not retained long term. For example, third-party scripts may receive page URLs, referrer information, timestamps, or interaction events that indicate a visitor’s attempt to seek care. A website does not need to maintain a patient record for third-party disclosure risk to exist.
Anonymization and IP masking can reduce certain types of exposure, but they do not automatically eliminate third-party access to healthcare context. Many analytics and tracking tools still receive page content, event metadata, timing information, or device-level signals that can imply healthcare-related activity. In addition, vendor posture and contractual safeguards remain critical. Even minimized data may be problematic if a vendor will not operate under HIPAA-aligned terms for the product in use.
HIPAA authorization requirements are specific and distinct from general website consent mechanisms such as cookie banners or terms-of-use acceptance. Valid HIPAA authorization must meet detailed content and process requirements and is typically impractical to implement consistently for website tracking technologies. As a result, general consent signals rarely resolve website-level HIPAA exposure risk on their own, particularly when third-party vendors do not support HIPAA-aligned safeguards.
Homepage usage still requires evaluation. A homepage that clearly represents a medical practice, lists services, or links directly into care-seeking pathways can create healthcare context even without explicit form submissions. Risk may escalate further as users navigate from the homepage into scheduling, intake, or service pages. Assessment focuses on content, user flow, and downstream interaction rather than page type alone.
Links to external patient portals can expose referrer data and page context, particularly if the linking page references specific services, conditions, or providers. While patient portals themselves may be HIPAA-compliant systems, the transition from a public website to a portal should be designed to minimize unnecessary disclosure. Practices often use neutral landing pages, referrer controls, or other isolation techniques to reduce exposure.
Yes. Telehealth websites frequently involve direct care-seeking actions such as scheduling, intake, account access, and virtual visit workflows. These interactions strengthen healthcare context and increase sensitivity around third-party tracking technologies. Telehealth providers have also received heightened attention regarding online tracking, making careful evaluation of website tools particularly important.
Yes. HIPAA obligations apply regardless of nonprofit status, mission, or funding model. Community clinics and nonprofit providers often serve vulnerable populations, which can heighten sensitivity around privacy and trust even when resources are limited. Regulatory expectations do not change based on organizational structure.
Accessibility overlays and translation widgets are often deployed for important reasons, but they may introduce additional third-party access to page content or user behavior. These tools are typically evaluated as contextual risk surfaces, especially when they load on patient-action pages. In some cases, first-party or server-side alternatives can reduce exposure while still supporting accessibility and language needs.
No. The presence of a third-party tool does not automatically make it disallowed. Risk depends on the tool’s purpose, vendor posture, contractual safeguards, and how it is used within the site. Some tools can be used safely with appropriate isolation or HIPAA-aligned agreements, while others create architectural risk that cannot be reliably constrained.
Yes. Website risk can reappear due to vendor updates, new marketing campaigns, configuration changes, or staff turnover. A site that is clean at one point in time may accumulate new risk without intentional oversight. Ongoing monitoring helps detect reintroduced risk early, before it becomes widespread or operationally disruptive.
No. Privacy Examiner does not report practices to regulators, enforcement agencies, or third parties unless your notification came from an insurance carrier or underwriter using our services. Our role is informational and supportive, providing practices with visibility into their own websites so they can make informed, voluntary decisions about remediation and monitoring.
Remediation may change how marketing performance is measured, but it does not inherently reduce search visibility or patient access. Many practices maintain or improve SEO performance by focusing on content quality, local optimization, and user experience while shifting away from invasive tracking techniques that are not appropriate for regulated environments.
Practices receive documentation describing detected findings, remediation actions taken, and monitoring results over time. This documentation supports internal decision-making, vendor coordination, and demonstration of due diligence if questions arise later.
Website risk management is ongoing. Technologies evolve, vendors update products, and regulatory expectations continue to develop. Treating website privacy as a one-time project can allow risk to quietly return over time, which is why many practices choose ongoing monitoring rather than a single review.
