Overview / Goals
Design a HIPAA-compliant migration that protects PHI, minimizes downtime, documents controls for auditors, and secures BAAs with cloud providers.
1. Risk assessment
- Conduct Data Inventory & Classification (identify PHI locations, data flows).
- Threat modeling (insider threat, misconfig, exfiltration) and quantitative risk scoring.
- Prioritize systems by risk and business criticality; create migration waves.
2. HIPAA & BAAs
- Map HIPAA administrative, physical, technical safeguards to cloud controls.
- Execute BAAs with CSP and any third-party vendors before any PHI transfer.
- Validate vendor compliance posture (SOC 2, HITRUST, compliance docs).
3. De-identification / pseudonymization
- Apply Safe Harbor or Expert Determination approaches per use case.
- Use tokenization/pseudonymization services for intermediate staging; retain re-identification keys in an HSM-controlled vault.
- For analytics, store only de-identified datasets.
4. Encryption
- In transit: TLS 1.2+ with strong ciphers.
- At rest: AES-256 with customer-managed keys (KMS/HSM). Rotate keys and maintain key access logs.
- Backup encryption and key escrow procedures.
5. Access controls
- Principle of least privilege, role-based access (RBAC) + attribute-based controls for sensitive APIs.
- Enforce MFA, conditional access, Just-In-Time privileged access, and separation of duties.
- Use VPC, private endpoints, and firewall rules to restrict network access.
6. Monitoring, logging & audit evidence
- Centralized immutable logging (cloud audit logs, VPC flow logs) forwarded to SIEM and long-term secure storage with retention policies.
- Enable object-level access logs and KMS key usage logs.
- Implement automated compliance checks (CIS/HIPAA frameworks) and produce audit-ready evidence bundles (config snapshots, policy attestations, BAA copies).
7. Ops, testing & validation
- Run pilot migrations, continuous vulnerability scanning, penetration tests, and tabletop incident response exercises.
- Backup/rollback plans; validate restore procedures with PHI scrubbed test data.
8. Governance & documentation
- Maintain Architecture Decision Records, control mappings to HIPAA, change control, and ongoing vendor reassessments.
- Train teams on PHI handling and monitor third-party access.
Outcome: phased, auditable migration that enforces HIPAA safeguards, preserves re-identification controls, and produces regulator-ready evidence.
