Disclaimer & Boundaries

This page defines the scope, limitations, assumptions, and boundaries of Privacy Examiner’s services. It is intended to provide clear expectations for healthcare organizations, advisors, and other stakeholders regarding what Privacy Examiner does, how our findings should be interpreted, and how our work fits within broader HIPAA compliance, legal, and operational frameworks.

Privacy Examiner was designed to operate with discipline, restraint, and evidentiary rigor. The boundaries described below are not incidental. They are foundational to maintaining credibility, regulatory alignment, and defensibility.

Our Role and Mission Scope

Privacy Examiner is an independent website risk detection and monitoring company focused exclusively on identifying externally observable website technologies, configurations, and architectural patterns that may create HIPAA exposure risk for healthcare organizations.

Our work is limited to the public-facing digital surface of a healthcare organization’s website. We assess what is visible from the outside, using non-invasive, evidence-based techniques, to determine whether known categories of tracking technologies, third-party integrations, hosting environments, and page-level behaviors are present.

We operate as an examiner and risk assessor. We do not function as a regulator, auditor of record, certifying body, or enforcement authority. We also do not replace or supersede the role of legal counsel, compliance officers, internal IT teams, or external advisors.

Our mission is to make website-level privacy risk visible, understandable, and actionable so healthcare organizations can make informed decisions and document good-faith risk management.

Not Legal Advice

Privacy Examiner is not a law firm and does not provide legal advice.

Nothing on this website, in our reports, in written communications, or in verbal discussions should be interpreted as legal advice, legal conclusions, or regulatory determinations. Our findings are not a substitute for advice from qualified legal counsel.

Healthcare organizations should consult their attorneys for:

  • Interpretation of HIPAA statutes and regulations
  • Applicability of OCR guidance to specific factual scenarios
  • Assessment of enforcement risk
  • Breach notification obligations
  • Contractual, indemnification, or liability matters

Our role is limited to identifying technical and architectural risk surfaces and explaining why those conditions are commonly associated with HIPAA exposure in a healthcare context.

No HIPAA Compliance Certification or Guarantees

Privacy Examiner does not certify HIPAA compliance, guarantee compliance outcomes, or provide assurances regarding regulatory enforcement, investigations, or penalties.

HIPAA compliance is an organization-wide, fact-specific obligation that depends on policies, procedures, workforce training, access controls, contracts, safeguards, governance practices, and operational behavior across many systems.

Website risk assessment is only one component of that broader compliance posture.

Accordingly:

  • We do not issue compliance certifications
  • We do not provide “HIPAA compliant” seals or badges
  • We do not guarantee that remediation eliminates all risk
  • We do not warrant regulatory outcomes

Our services are designed to support risk reduction, documentation of due diligence, and ongoing monitoring—not to declare compliance.

Risk-Based Findings and Internal Standards

Privacy Examiner reports findings as risk signals, not confirmed violations.

Our classifications are based on publicly observable evidence, including:

  • Website source code and rendered content
  • Network requests initiated by the website
  • Third-party scripts, pixels, and embedded services
  • Page context, such as forms, scheduling, or care-seeking flows
  • Known vendor posture regarding Business Associate Agreements (BAAs)

When we describe a condition using terms such as high-confidence, architectural risk, unacceptable, or disallowed, those terms reflect Privacy Examiner’s internal risk standards.

These standards are intentionally conservative and are designed to help healthcare organizations make operational decisions under uncertainty.

Such classifications:

  • Are not legal conclusions
  • Are not regulatory determinations
  • Do not represent findings by HHS, OCR, or any government authority

Where external guidance exists, we align our interpretation to regulator-recognized risk mechanisms while applying a stricter operational posture focused on patient privacy and risk avoidance.

External Observation and Non-Invasive Methods

Privacy Examiner’s reviews are limited to externally observable evidence.

We rely on techniques that do not interact with protected systems or simulate patient behavior. Our methods are designed to be non-invasive, repeatable, and defensible.

We may observe:

  • Public page HTML and rendered DOM content
  • Network calls made by a browser when loading pages
  • Response headers and cookies where accessible
  • Publicly reachable URLs, assets, and scripts

We do not:

  • Submit forms or enter information into fields
  • Attempt to access patient portals or authenticated areas
  • Access backend systems, databases, or server logs
  • Inspect internal vendor accounts or dashboards
  • Test authentication controls or security defenses

Because of these constraints, our findings should be understood as indicators of potential exposure pathways, not a complete audit of all data handling practices.

Vendor and Technology References

When specific vendors, platforms, or technologies are named, it is because detection was deterministic and materially relevant to understanding remediation options.

Mention of a vendor or product does not imply intent, negligence, fault, or wrongdoing by any organization or individual.

Many healthcare website risks arise from:

  • Standard marketing configurations
  • Legacy website builds
  • Third-party tools designed for consumer or retail use
  • Vendor defaults not tailored for HIPAA-regulated environments

Our focus is on technical behavior and architectural realities, not assigning blame.

Limits of Assurance and No Guarantees

Privacy Examiner does not guarantee:

  • Elimination of all privacy or compliance risk
  • Prevention of regulatory inquiries or complaints
  • Avoidance of investigations or audits
  • Specific enforcement or penalty outcomes
  • Future compliance status

Digital environments change continuously. Websites are updated, vendors modify products, scripts are reintroduced, and configurations drift over time.

Risk reduction is therefore an ongoing process.

Our role is to help identify risk surfaces, support remediation decisions, and provide monitoring so changes do not quietly reintroduce exposure.

Relationship to Other Advisors and Vendors

Privacy Examiner is designed to work alongside, not in place of:

  • Legal counsel
  • Compliance and privacy officers
  • Internal IT and security teams
  • Marketing agencies and web developers

We provide independent visibility and documentation that these stakeholders can use to:

  • Prioritize remediation
  • Validate assumptions
  • Support internal decision-making
  • Document good-faith efforts

We do not implement code changes unless separately contracted, and we do not assume responsibility for vendor performance or ongoing site management.

Appropriate Use of Information

Information provided by Privacy Examiner should be used to:

  • Understand potential website-level privacy exposure
  • Inform remediation planning and prioritization
  • Support internal and vendor conversations
  • Document reasonable diligence and monitoring

It should not be used as:

  • Legal advice
  • Proof of regulatory compliance
  • A substitute for organizational risk analysis
  • A representation of enforcement status

Jurisdictional and Regulatory Context

Privacy Examiner operates within the United States regulatory context and primarily references U.S. HIPAA and HHS OCR guidance.

Healthcare organizations operating in multiple jurisdictions may be subject to additional privacy, security, or data protection obligations beyond HIPAA, including state laws or international frameworks.

Our findings do not address those obligations unless explicitly stated.

Questions, Clarification, and Next Steps

If you have questions about the scope of our services, how to interpret a finding, or how our internal classifications should be understood, we encourage you to request a confidential discussion.

Our goal is clarity, not alarm. We believe informed organizations make better decisions when risk is explained plainly, boundaries are respected, and remediation options are presented without pressure.

 

Privacy Examiner is not a law firm and does not provide legal advice or certify HIPAA compliance. Findings are based on externally observable website evidence and presented as risk indicators to support remediation and monitoring.