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Customers are responsible for implementing appropriate privacy and security safeguards within Adobe Sign, discussed further below, in order to protect Protected Health Information (PHI) in compliance with HIPAA.
The process starts with signing a HIPAA Business Associate Agreement (BAA).
Once the BAA is signed, Adobe Sign will adjust back-end settings that will cause the HIPAA Compliance setting on the Global Settings page to show as checked, indicating that it is enabled.
Note that this setting is view only and never editable by the customer admin.
This article is meant for Customers who have a BAA in place with Adobe Sign. Customers that do not have a BAA may not enable this setting.
The following are general security recommendations from Adobe to harden your Adobe Sign account for use with PHI data.
It is the customer's responsibility to consider these and all other Adobe Sign security features and apply them as needed to protect the electronic protected health information (ePHI) stored in Adobe Sign.
It is strongly recommended that the account use SAML authentication.
- Accounts that manage user entitlement via the Adobe Admin Console can find those instructions here.
- Accounts using Adobe Sign's native identity system can access their SAML settings by logging in as an account-level admin and navigating to Account Settings > SAML Settings
- The SAML Mode should be set to Mandatory
- The SAML Mode should be set to Mandatory
Accounts that manage their users within the Adobe Sign web application (not going through the Adobe Admin Console or SAML) should configure strong authentication controls.
Log in as an account-level admin and:
- Navigate to Account Settings > Security Settings
- Configure:
- Single Sign-on Settings:
- Disable Adobe ID
- Disable OpenID
- Remember-me Settings:
- Disable the Remember-me Settings
- Login Password Policy (Note: Accounts that manage entitlements via the Adobe Admin Console will not have access to these controls):
- Enable password duration policy and require the password be changed every 3 months (or fewer)
- Enable password history policy and prevent reuse of the last 10 (or more) passwords
- Allow users 5 (or fewer) attempts to login before locking their accounts
- Enable password duration policy and require the password be changed every 3 months (or fewer)
- Login Password Strength:
- Set to Strong
- Accounts that use the Adobe Admin Console should configure the account to More Secure
- Web Session Duration:
- Set to 10 minutes of inactivity
- Single Sign-on Settings:
- Save your changes
Email is generally considered a less secure medium when sending electronic personal health information as there are several ways that notifications can be a source of ePHI leakage.
Keep in mind that the name of the agreement is listed in the notification, so patient information (eg, names) should never be used in the title of the agreement.
Additionally, the agreement itself contains ePHI, and so attaching the agreement to the notifications can expose ePHI if the email is intercepted.
- Navigate to Account Settings > Global Settings > Attach a PDF copy of the signed document in emails
- Set the value to No One
- Uncheck Include a link in emails to view the signed agreement
- Uncheck Include an image of the first page of the agreement in emails
- Save the changes
Caution:
Do not use personal information in the names of Adobe Sign agreements. Agreement names are exposed within emails.
Note:
We strongly recommend that account administrators review the other security settings in Account Settings > Security Settings
Before processing protected health information through Adobe Sign, your organization must enter into a Business Associate Agreement with Adobe.
Note:
Only enterprise and business tiers of service are eligible for a BAA, but not all accounts qualify.
Contact your sales or channel representative to determine eligibility and establish a BAA with Adobe.