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CCPA & HIPAA Compliance

The California Consumer Privacy Act (CCPA/CPRA) and the Health Insurance Portability and Accountability Act (HIPAA) are two major US regulations that impose requirements on how organizations handle personal and health-related data. While they serve different populations and industries, they share common themes: data inventory, access control, audit logging, breach response, and formal data sharing agreements. Qarion provides the governance infrastructure to address both.

CCPA / CPRA​

The CCPA grants California consumers the right to know what personal information is collected about them, to request deletion, and to opt out of the sale or sharing of their data. The CPRA (the 2023 amendment) strengthened these rights and introduced data minimization and purpose limitation requirements.

Consumer Data Inventory​

CCPA Sections 1798.100–1798.110 require businesses to disclose the categories of personal information they collect and the purposes for which it is used. Qarion supports this through:

  • Data Catalog — Every data asset containing consumer information can be cataloged with classification metadata (e.g., PII, sensitive personal information), source, purpose, and retention details.
  • Tagging and categorization — Flexible tags allow organizations to label assets by data category (identifiers, geolocation, biometric, etc.) as defined by the CCPA.
  • Full-text search — Quickly identify all data products that contain specific types of consumer information across the entire organization.

Access Request Tracking​

When consumers submit access, deletion, or opt-out requests, organizations need to verify, track, and fulfill them within defined timelines. Qarion provides:

  • Self-service access requests — The access management system tracks every request with timestamps, justification, and approval status — a pattern that maps directly to consumer request management.
  • Approval workflows — Configurable workflows route requests through appropriate review steps, ensuring proper verification before data is disclosed or deleted.
  • Audit trails — Every request and its outcome are logged, providing the documentation needed to demonstrate compliance during regulatory inquiries.

Data Flow Mapping​

CCPA requires businesses to understand how consumer data flows through their systems, especially for disclosure and deletion purposes. Qarion's lineage capabilities support this:

  • Data lineage graphs — Interactive visualization shows how consumer data moves from source systems through transformations to downstream consumers, making it possible to identify all locations where data must be disclosed or deleted.
  • Impact analysis — Assess which downstream systems and processes would be affected by a deletion request before executing it.

Data Sharing Agreements​

The CPRA imposes restrictions on data sharing and requires service provider and contractor agreements. Qarion's Data Contracts support this by:

  • Formalizing data sharing terms — Contracts between data producers and consumers define what data is shared, for what purpose, and under what conditions.
  • SLA tracking — Monitor whether data handling terms are being met, with breach notifications when SLAs are violated.

Breach Response​

CCPA Section 1798.150 establishes a private right of action for data breaches involving unencrypted personal information. Rapid detection and response are critical:

  • Smart Alerts — Centralized alert aggregation catches anomalies that could indicate a breach.
  • Issue management — Structured incident tracking with resolution debriefs documents the organization's response to breaches.
  • Notification workflows — Automated workflows ensure the right stakeholders are informed immediately when a potential breach is detected.

HIPAA​

HIPAA applies to covered entities (health care providers, health plans, clearinghouses) and their business associates. It establishes national standards for protecting individuals' electronic protected health information (ePHI) through the Privacy Rule, Security Rule, and Breach Notification Rule.

Minimum Necessary Access​

The HIPAA Privacy Rule's "minimum necessary" standard requires that access to PHI be limited to what is needed for a specific purpose. Qarion enforces this through:

  • Fine-grained RBAC — Permission rules restrict access to specific data products based on user roles. Permissions are scoped by Space, ensuring that users in one department cannot access PHI managed by another.
  • Self-service access requests — Rather than granting broad access, users request access to specific data products with a documented justification. Requests are reviewed by data owners before approval.
  • Approval workflows — Multi-step approval workflows ensure that access to PHI goes through appropriate review, with role-based approver resolution (e.g., Data Owner must approve).

Audit Controls​

The HIPAA Security Rule (§ 164.312(b)) requires mechanisms to record and examine activity in information systems that contain ePHI. Qarion provides:

  • Complete audit trails — Every access request, approval, login, data change, and governance action is logged with timestamps and actor attribution.
  • Activity feeds and notifications — Real-time visibility into who is accessing what data and when.
  • Governance meeting records — Scheduled reviews with documented agendas, participants, decisions, and action items provide evidence of ongoing compliance monitoring.

Business Associate Agreements​

HIPAA requires covered entities to have written agreements (BAAs) with business associates that handle PHI. Qarion's Data Contracts support this by:

  • Defining data handling terms — Contracts specify what data is shared, the permitted uses, security requirements, and breach notification obligations between parties.
  • SLA monitoring — Track whether business associates are meeting their contractual obligations, with alerts when terms are breached.
  • Producer-consumer relationships — The contract system explicitly models the relationship between data providers (covered entities) and data consumers (business associates), preserving accountability.

Incident Response and Breach Notification​

The HIPAA Breach Notification Rule (§ 164.400–414) requires notification of breaches affecting 500+ individuals within 60 days. Qarion supports rapid incident response:

  • Smart Alerts Center — Aggregates technical and governance events that could indicate a breach, providing centralized monitoring.
  • Issue management — Incidents are tracked through a structured lifecycle with assignment, investigation, resolution debriefs, and impact assessment.
  • Workflow orchestration — Automated notification workflows ensure that breach response procedures are triggered immediately, routing alerts to compliance officers, legal teams, and affected business units.
  • Impact assessment — Link affected data products to incidents to quantify the scope of a breach and determine notification obligations.

Periodic Access Reviews​

HIPAA requires ongoing evaluation of access controls to ensure they remain appropriate. Qarion supports this through:

  • Governance meetings — Schedule periodic access reviews with structured agendas and action item tracking.
  • Recertification workflows — Automated processes to periodically review and recertify that user access to PHI remains justified and appropriate.
  • Permission rule management — Centralized visibility into all active permission rules, making it easy to audit and adjust access as roles and responsibilities change.