Check a vendor
Check a vendor
Answer the four questions to see whether this vendor needs a BAA.
If a vendor can reach the data, it's a business associate. Encryption without the key doesn't change that. HHS said so.Your engineer
Who signs, and who doesn't
From the vendors' own documentation, checked in October 2026. Terms change; confirm with the vendor before relying on any line.
| Vendor | BAA? | Condition |
|---|---|---|
| Microsoft 365, Azure | Yes | Included by default in the Data Protection Addendum for covered entities and business associates |
| Google Workspace, Google Cloud | Yes | Accepted by a super admin in the Admin console; not the legacy free edition, non-admin users or consumer Gmail |
| AWS | Yes | Self-service through AWS Artifact; PHI only in HIPAA-eligible services |
| Zoom | Yes | A standard BAA exists; plan eligibility isn't stated publicly, so ask |
| Slack | Yes | Enterprise plan only, and not for communicating with patients |
| Dropbox | Yes | Standard, Business, Advanced, Business Plus and Enterprise; not consumer plans |
| Box | Yes | Enterprise, Enterprise Plus and Enterprise Advanced accounts |
| Notion | Yes | Enterprise plan only |
| HubSpot | Yes | Enterprise subscriptions with Sensitive Data enabled; accepted in-product |
| Twilio | Yes | Security or Enterprise edition, HIPAA-eligible products only |
| DocuSign | Yes, by agreement | DocuSign describes itself as a business associate for healthcare customers; the plan isn't stated publicly, so ask |
| Calendly | No | Calendly says it doesn't offer a BAA and isn't intended for PHI |
| Mailchimp | No | Terms put HIPAA suitability on you and disclaim liability; no BAA is offered on its site |
| Stripe | No | Its agreement prohibits sending it PHI |
| Zapier | No | States it doesn't offer a BAA |
| Canva | No public BAA | Nothing on its compliance pages; assume no |
The vendors practices forget
- The e-fax service. It stores every fax. Business associate.
- The copier lessor, if it services the machine and can access the drive.
- The appointment reminder and review-request platform. It has the patient list.
- The answering service that takes after-hours calls.
- The accountant or lawyer who sees records in the course of their work.
- Your own subcontractors, if you're a business associate. The chain doesn't stop at you.
What goes in the agreement
HHS publishes sample provisions, and most large vendors have their own form. Either way it must cover permitted uses and disclosures, safeguards and Security Rule compliance, reporting of breaches and incidents, flow-down to subcontractors, support for patient rights, return or destruction of PHI at the end, and termination for breach. The negotiable parts are the reporting window, audit rights, insurance and indemnities. See HIPAA for business associates for the vendor's side of the table.
With AccuSights: the business associate inventory lives in the platform with the agreement, the owner and the renewal date for each vendor, reminders go out before anything lapses, and the whole list is one tab of the documentation pack when OCR or a customer asks.