Is Google Tag Manager HIPAA compliant?

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Google Tag Manager is a tool that many use to simplify the process of managing various tracking codes and tags on websites. However, healthcare organizations that handle protected health information (PHI) need to ensure that the tools they use are HIPAA compliant. This article evaluates whether Google Tag Manager is HIPAA compliant.

What is Google Tag Manager?

Google Tag Manager (GTM) is a tool that allows marketers and website administrators to manage and deploy tracking tags on websites without requiring direct code modification. Instead of manually inserting individual tags into website code, Google Tag Manager provides a centralized interface where users can add, edit and control various tags, including analytics tracking codes, conversion tracking pixels and marketing tags .

Related: Is Online Tracking HIPAA Compliant?

What data does Google Tag Manager monitor?

According to Google, “Google Tag Manager may collect certain aggregate data about tag activation. This data does not include users’ IP addresses or any measurement identifiers associated with a particular individual. Other than data in standard HTTP request logs, which they are all deleted within Within 14 days of receiving and receiving the above diagnostic data, Google Tag Manager does not collect, retain or share any information about visitors to our clients’ properties, including the URLs of the pages visited.

Does using Google Tag Manager need to be HIPAA compliant?

Google Tag Manager is designed to insert tracking code like Google Analytics into a website. Google Tag Manager might be better thought of as a vehicle for implementing other services which, in turn, manage PHI. Therefore, when used with HIPAA compliant tracking tools, your use of GTM may be HIPAA compliant.

However, Google states: “Customers should not use Google Analytics in any way that could create obligations under HIPAA for Google. HIPAA-regulated entities using Google Analytics should not expose to Google any data that may be considered Protected Health Information (PHI), even if not expressly described as personal information in Google’s agreements and policies. Google does not guarantee that Google Analytics meets HIPAA requirements and does not offer business associate agreements with respect to this service. “

While the use of code injectors such as Google Tag Manager is not directly prohibited by HIPAA, code added by GTM must be HIPAA compliant.

Provisions relating to the Business Association Agreement (BAA).

Under HIPAA, a business associate is an entity or individual who performs certain functions or activities on behalf of a covered entity, typically involving access to PHI. As a GTM provider, Google would be considered a business partner if it is handling PHI on behalf of a covered entity.

A business associate agreement (BAA) is a legal contract between a covered entity and a business associate. Establishes the business associate’s responsibilities and obligations regarding the management and protection of PHI. A BAA is required to ensure that both parties comply with HIPAA regulations and implement appropriate security measures when PHI is involved.

Is Google Tag Manager covered by the Google BAA?

Google Cloud Platform and Google Workspace offer HIPAA compliant products, and Google provides a BAA for these specific product suites. However, Google Tag Manager is not in the list of HIPAA compliant services offered by Google.

Is Google Tag Manager HIPAA compliant?

While GTM offers security features and Google provides a BAA for some Google products, the HIPAA compliance status of GTM itself is not explicitly stated by Google. Google Tag Manager is not listed among the services covered by Google’s BAA provisions. Therefore, the use of Google Tag Manager may not be HIPAA compliant when used to implement Google Analytics.

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