Organizations investing IS HITRUST Report Can Be Shared With Others certification often wonder about one critical aspect of their assessment results: Can HITRUST reports be shared with others? The short answer is yes, but with important caveats and specific guidelines that must be followed.
IS HITRUST Report Can Be Shared With Others contain sensitive information about your organization’s security posture and compliance status. While these reports can demonstrate your commitment to data protection and regulatory compliance to clients and partners, sharing them requires careful consideration of confidentiality requirements, proper protocols, and potential risks.
This guide will walk you through everything you need to know about sharing HITRUST reports, including when it’s appropriate, what precautions to take, and how to avoid potential pitfalls that could compromise your organization’s security or legal standing.
Contents
What is a HITRUST Report?
A HITRUST report documents the results of an assessment conducted under the IS HITRUST Report Can Be Shared With Others Common Security Framework (CSF). This framework provides a comprehensive, standardized approach to managing information security risks across various industries, with particular emphasis on healthcare organizations that handle protected health information (PHI).
The HITRUST CSF incorporates requirements from multiple regulatory standards, including HIPAA, HITECH, PCI DSS, and ISO 27001, creating a unified framework that addresses overlapping compliance needs. Organizations undergo rigorous assessments to evaluate their security controls against these standards.
HITRUST assessments come in different forms, each producing specific types of reports:
Validated Assessment (v1) produces the most comprehensive report, involving extensive testing and validation by HITRUST-approved assessors. These assessments typically take several months to complete and result in detailed reports showing control implementation across all assessed areas.
Readiness Assessment (r2) provides a preliminary evaluation of an organization’s security posture. While less rigorous than validated assessments, r2 reports still contain valuable information about control maturity and compliance status.
Implementation Assessment (i1) focuses on documenting implemented controls without extensive testing. These reports demonstrate an organization’s efforts to implement required security measures but don’t provide the same level of validation as v1 assessments.
Understanding the Confidentiality of HITRUST Reports
HITRUST treats assessment reports as confidential documents containing proprietary information about an organization’s security infrastructure, processes, and potential vulnerabilities. This confidentiality serves multiple purposes: protecting competitive advantages, preventing security information from falling into the wrong hands, and maintaining the integrity of the assessment process.
The sensitive nature of these reports stems from their detailed examination of security controls, identification of gaps or weaknesses, and documentation of remediation efforts. If disclosed inappropriately, this information could potentially be exploited by bad actors or competitors.
Legal and regulatory considerations also influence confidentiality requirements. Many organizations operate under strict data protection regulations that require careful handling of security-related documentation. Additionally, contractual obligations with clients, vendors, or business partners may include specific requirements about how security assessments and reports are managed and shared.
HITRUST’s confidentiality policy reflects these concerns while recognizing that organizations have legitimate business needs to share assessment results with appropriate parties under controlled circumstances.
Situations Where Sharing is Permitted
Organizations can share HITRUST reports in several specific situations, provided they follow proper protocols and obtain necessary approvals.
Sharing with Clients and Business Partners
Many organizations pursue HITRUST certification specifically to demonstrate their security posture to clients, particularly in healthcare, financial services, and other regulated industries. Clients increasingly require evidence of robust security programs before entering into business relationships or renewing contracts.
When sharing with clients or business partners, organizations should establish clear parameters through non-disclosure agreements (NDAs) that specify how the report will be used, who will have access, and what protections will be in place. The NDA should also address how long the receiving party can retain the report and requirements for returning or destroying it when no longer needed.
Vendor relationships often require similar sharing arrangements. Organizations may need to provide HITRUST reports to demonstrate their security capabilities when bidding on contracts or during vendor assessment processes.
Regulatory and Audit Sharing
Regulatory bodies and external auditors represent another category of authorized recipients for HITRUST reports. Healthcare organizations may need to provide these reports to demonstrate compliance with HIPAA requirements during audits or investigations by the Department of Health and Human Services.
Similarly, financial services organizations might share HITRUST reports with banking regulators or during compliance examinations. In these cases, the sharing is typically mandated by regulatory requirements rather than voluntary business decisions.
External auditors conducting annual financial audits or specialized security assessments may also require access to HITRUST reports to complete their work effectively.
Internal Organizational Sharing
Within organizations, HITRUST reports can be shared with relevant stakeholders who need access to assessment results for business purposes. This typically includes senior executives, security teams, compliance officers, and legal counsel.
However, even internal sharing should follow the principle of least privilege, ensuring that individuals receive only the information necessary for their specific roles and responsibilities.
Best Practices for Sharing a HITRUST Report
Following established best practices helps ensure that HITRUST report sharing remains secure, compliant, and beneficial for all parties involved.
Obtain Written Consent
Before sharing a HITRUST report with any external party, organizations should obtain written consent from HITRUST. This consent process ensures that sharing aligns with HITRUST policies and provides documentation that proper approval was obtained.
The consent process typically involves submitting a request that describes the intended recipient, purpose of sharing, and specific protections that will be implemented. HITRUST reviews these requests and provides guidance on appropriate sharing parameters.
Redact Sensitive Information
Not all information in a HITRUST report needs to be shared with every recipient. Organizations should carefully review reports and redact information that isn’t relevant to the recipient’s needs or that could pose security risks if disclosed.
Common redaction targets include specific technical details about security implementations, names of internal personnel, detailed vulnerability descriptions, and information about unrelated business operations.
Use Secure Sharing Methods
HITRUST reports should never be shared through unsecured channels like standard email or file-sharing platforms without proper encryption and access controls. Instead, organizations should use secure methods such as encrypted email systems, secure file transfer protocols, or dedicated client portals with authentication requirements.
Consider implementing additional security measures like password protection, access expiration dates, and download tracking to maintain control over shared documents.
Track Report Recipients
Maintaining detailed records of who receives HITRUST reports, when they receive them, and for what purpose helps organizations manage ongoing compliance obligations and respond quickly if security concerns arise.
This tracking should include contact information for recipients, copies of signed NDAs or other agreements, and any specific limitations or conditions associated with each sharing arrangement.
Risks of Unauthorized Sharing
Sharing HITRUST reports without proper authorization or controls can expose organizations to significant risks across multiple dimensions.
Legal and Financial Consequences
Unauthorized disclosure of HITRUST reports may violate contractual obligations with HITRUST, potentially resulting in loss of certification or legal action. Organizations might also face breach of contract claims from clients or partners if sharing violates established confidentiality agreements.
Financial penalties can extend beyond direct legal costs to include regulatory fines if unauthorized sharing violates data protection requirements or industry-specific regulations.
Reputational Damage
Trust represents a critical asset for organizations handling sensitive data. Inappropriate sharing of security assessments can damage relationships with clients, partners, and stakeholders who rely on the organization’s commitment to protecting confidential information.
Recovery from reputational damage often proves more costly and time-consuming than addressing the immediate consequences of unauthorized disclosure.
Security Posture Compromise
Perhaps most significantly, unauthorized sharing can directly compromise the security benefits that HITRUST certification is intended to provide. Detailed security information in the wrong hands could enable targeted attacks or provide insights that help bad actors circumvent existing protections.
Even if shared information doesn’t directly enable attacks, it might reveal enough about security practices to reduce their effectiveness or highlight potential vulnerabilities for exploitation.
Frequently Asked Questions
Can I share my HITRUST report with potential clients during sales processes?
Yes, you can share HITRUST reports with potential clients, but you should obtain written consent from HITRUST first and ensure proper NDAs are in place. Consider providing a summary or redacted version that demonstrates your certification status without exposing sensitive security details.
How long is written consent from HITRUST valid?
HITRUST consent terms vary depending on the specific sharing arrangement, but organizations should verify current consent status before each sharing instance. It’s good practice to review and renew consent agreements annually or when circumstances change significantly.
What should I do if someone requests our full HITRUST report but only needs certification verification?
Consider whether the requesting party actually needs the full report or if a certification letter or summary document would meet their requirements. HITRUST provides verification services that can confirm certification status without requiring full report disclosure.
Are there penalties for sharing HITRUST reports without proper authorization?
Yes, unauthorized sharing can result in certification suspension or revocation, legal action from HITRUST, and potential breach of contract claims. Organizations should always follow proper authorization procedures before sharing assessment results.
Can we share HITRUST reports with our cyber insurance provider?
Insurance providers may require access to security assessments as part of their underwriting or claims processes. This sharing is typically permissible but should still follow proper consent and confidentiality procedures to ensure compliance with HITRUST requirements.
Moving Forward with Confidence
HITRUST reports can be valuable tools for demonstrating your organization’s commitment to security and compliance, but sharing them requires careful attention to established protocols and best practices. The key lies in understanding when sharing is appropriate, following proper authorization procedures, and implementing adequate protections for shared information.
Organizations that take a thoughtful, systematic approach to HITRUST report sharing can leverage their certification investments to build stronger business relationships while maintaining the security and compliance benefits that motivated their initial certification efforts.
Before sharing any HITRUST report, consult with your legal team, review current HITRUST policies, and ensure you have proper consent and protections in place. This proactive approach will help you maximize the business value of your HITRUST certification while avoiding the significant risks associated with unauthorized disclosure.
