Outreach & HIPAA Compliance

Executive Summary

Outreach can support customers operating in HIPAA-regulated environments when a Business Associate Agreement (BAA) is in place and customers configure and use the platform in accordance with the terms of that agreement. Outreach maintains a HIPAA attestation and offers BAAs to customers who require them and meet specific requirements.

This article is intended solely for customers who have executed a BAA with Outreach. Customers who have not executed a BAA are not permitted to store, process, or transmit protected health information (PHI) within the Outreach platform.

Outreach does not provide legal advice. Customers are solely responsible for determining the specific controls, configurations, policies, and risk tolerance appropriate for their business operations and compliance obligations. Customers should consult their legal counsel and compliance professionals to assess their organization’s HIPAA requirements.

This article is intended for informational purposes only and does not constitute legal advice, a comprehensive risk assessment, or a complete HIPAA control mapping. It also does not provide full traceability to HIPAA requirements.

HIPAA and the Outreach Platform

Healthcare and life sciences organizations use Outreach to align revenue teams and improve operational efficiency. Where PHI may be involved, customers must ensure their implementation, configuration, and operational practices align with HIPAA requirements and the obligations set forth in their BAA with Outreach.

As with any SaaS or AI-enabled technology, improper configuration or use may increase the risk of impermissible disclosures, including incidental or unintended exposure of PHI. HIPAA compliance in Outreach is therefore a shared responsibility: Outreach provides contractual safeguards and platform-level controls, while customers are responsible for governing user behavior, data flows, and administrative safeguards.

Customers act as the covered entity (or business associate, as applicable) and retain full responsibility and discretion for determining appropriate use of the platform, including what data is ingested, how it is processed, and what safeguards are implemented in alignment with their compliance obligations.

Data Protection Considerations

Synchronization of PHI into Outreach

Outreach is a revenue orchestration platform designed to support sales engagement workflows. Customers should carefully evaluate whether and to what extent PHI is introduced into the platform, including the risk of incidental or unintended ingestion through connected systems and user activity.

Potential entry points for PHI include:

• Email synchronization from connected inboxes
• Call recordings and transcripts
• Conversation intelligence outputs
• User-entered notes, tags, and custom fields

Customer Considerations and Best Practices:

• Conduct data mapping exercises to understand where PHI resides and how it flows into Outreach.
• Apply data minimization principles and avoid storing PHI in free-text fields, notes, emails, or recordings unless operationally necessary and contractually supported.
• Segregate systems of record for PHI from systems used for sales engagement where feasible.
• Implement centrally managed storage and system boundaries to reduce the likelihood of synchronization of PHI.
• Use governance profiles and role-based access controls to enforce least-privilege access.
• Periodically review user permissions and remove access when roles change.
• Establish internal policies restricting the use of email and other communication channels for transmitting PHI, particularly in sales workflows.

Outreach Voice and Conversation Intelligence (Kaia)

Outreach Voice and conversation intelligence features (including call recording and transcription capabilities) may process data discussed during calls. When operating under a BAA, customers must verify that all applicable HIPAA protections have been activated for their voice services, including any protections required by integrated providers, before utilizing these features in any manner that may involve PHI.

These features may introduce elevated risk due to:

• Broad internal visibility of recordings and transcripts
• Potential external sharing of recordings or links
• Automated transcription and downstream data propagation

Customer Considerations and Best Practices:

• Confirm all required protections are in place prior to using voice features with PHI.
• Restrict or disable call recording functionality where PHI discussions are not appropriate.
• Limit internal visibility of recordings and transcripts using governance controls.
• Restrict external sharing of recordings, transcripts, or links.
• Train users to recognize when PHI may be discussed and apply appropriate handling practices.
• Train administrators to manage visibility and retention of recordings and transcripts.

Generative AI and Smart Assist Features

Outreach’s generative AI capabilities leverage third-party large language models to generate suggested communications. These models are not trained on customer-specific data.

Customers are responsible for evaluating whether PHI is being processed through these features and whether such use aligns with their HIPAA obligations and contractual terms.

Customer Considerations and Best Practices:

• Evaluate the applicability of AI features to workflows that may involve PHI.
• Avoid including PHI in prompts or AI-assisted communications unless permitted under your BAA and internal policies.
• Implement internal review processes for AI-generated content prior to external transmission.
• Apply data validation and cleanliness controls to upstream systems that feed Outreach.
• Restrict access to AI features where necessary using governance controls.

Administrative, Technical, and Organizational Safeguards

In addition to feature-specific considerations, customers should implement broader safeguards aligned to HIPAA requirements and internal risk tolerance.

Customer Considerations and Best Practices:

• Conduct periodic HIPAA risk assessments and document findings.
• Align retention and deletion settings with internal HIPAA policies.
• Implement workforce HIPAA training tailored to Outreach usage scenarios, with emphasis on identifying PHI across formats and preventing unintended disclosure.
• Establish internal policies governing what data may be entered into Outreach and through which channels.
• Use compliance traceability and data mapping technologies where appropriate.
• Engage legal, compliance, and data governance teams during implementation and periodic reviews.

Shared Responsibility Model

Outreach secures and operates the underlying infrastructure and platform application layers and provides administrative tools to support compliant configurations.

However, customers are responsible for:

• Determining whether and how PHI will be used in the platform
• Determining what HIPAA requirements are applicable to your business
• Configuring platform controls appropriately and maintaining configurations over time
• Managing user access and permissions
• Governing integrations and downstream vendors (not Outreach subprocessors)
• Monitoring for and responding to incidents involving PHI
• Defining their organization’s risk acceptance and compliance posture

Outreach’s ability to support HIPAA compliance is contingent upon the execution of a BAA and the customer’s adherence to the requirements and permitted uses outlined in that agreement.

Outreach requires customers to engage Professional Services (PS) resources to support the initial configuration and ongoing optimization of HIPAA-related controls. While these resources assist with implementation, customers remain responsible for defining the appropriate configuration based on their compliance obligations.

Final Notes

The examples and practices outlined above are intended to highlight common risk scenarios and mitigation approaches but are not exhaustive. Customers should perform their own assessments and implement controls appropriate to their specific environment.

For more information on platform features, configuration settings, and governance controls, customers can reference the Outreach Support Portal, Outreach University, or contact Outreach Support.

Again, this document is provided for informational purposes only and does not constitute legal advice. Customers should consult their legal counsel and compliance advisors to determine how HIPAA applies to their specific use of the Outreach platform.