Campaigner is not HIPAA compliant for any use that involves protected health information because it does not sign a Business Associate Agreement with HIPAA Covered Entities or Business Associates, so it should not be used to create, receive, maintain, or transmit protected health information in email marketing, automated messaging, or related contact management.
A Business Associate Agreement is required when a vendor performs functions or services for a regulated entity that involve access to protected health information. An email marketing platform typically stores recipient addresses, contact attributes used for segmentation, message content, and engagement data, and those data elements can become protected health information when they identify an individual and relate to healthcare services, payment, or health status. Using an email marketing platform without a Business Associate Agreement creates an impermissible vendor relationship when protected health information is involved.
HIPAA compliance risk is not limited to message text. A mailing list that contains patient identifiers and reflects a treatment relationship can be protected health information even if the email content is generic. Segmentation fields such as clinic location, service line, appointment type, diagnosis categories, procedure categories, or billing status can convert contact records and campaign logic into protected health information. Tracking pixels, click tracking, and campaign analytics can also create records connected to identifiable individuals when used in communications tied to care.
The HIPAA Privacy Rule also regulates marketing communications that use protected health information and requires an individual authorization in many cases, subject to specific exceptions and conditions. Authorization requirements are separate from vendor contracting requirements. A signed authorization does not remove the need for a Business Associate Agreement when a third party handles protected health information on behalf of a regulated entity.
Campaigner can be used for communications structured to remain outside HIPAA scope by excluding protected health information from the platform. That limitation requires controls that prevent uploading patient lists derived from treatment or payment systems, prevent storing patient identifiers within Campaigner contact records, and prevent message content that references an individual’s care, appointment, test, prescription, treatment, or balance. If a healthcare organization cannot maintain those boundaries, a HIPAA-aligned email solution that supports a Business Associate Agreement is required for email campaigns involving protected health information.