Oracle Eloqua can support HIPAA-compliant use only when the organization purchases and uses the Oracle Eloqua HIPAA Advanced Data Security Add-on Cloud Service, executes a HIPAA Business Associate Agreement with Oracle for the applicable services, and limits campaign design, data collection, user access, and integrations to HIPAA Privacy Rule, HIPAA Security Rule, and HIPAA Breach Notification Rule requirements for electronic protected health information.
Oracle publishes HIPAA-specific functionality for Eloqua that routes regulated communications through authenticated access rather than placing electronic protected health information in standard email content. Oracle states, “The Oracle Eloqua HIPAA Advanced Data Security Add-on Cloud Service (that is, the HIPAA add-on) enables marketers to interact directly with healthcare consumers in a secure and compliant way.” Use of the add-on includes secure communications workflows, authenticated portals, and role-based separation that restricts access to protected contact data to authorized administrators and approved users.
Oracle is willing to sign a HIPAA Business Associate Agreement for customers using eligible Oracle services, and the agreement must be in place before Oracle creates, receives, maintains, or transmits electronic protected health information on the organization’s behalf. A HIPAA Business Associate Agreement should match the subscribed services, address permitted uses and disclosures, require safeguards, require reporting of security incidents and breaches, and flow down restrictions to subcontractors.
Eloqua usage creates HIPAA risk when protected health information enters list fields, tags, segmentation attributes, campaign assets, web forms, landing pages, tracking parameters, or third-party connectors that replicate data outside the secured workflow. HIPAA Privacy Rule controls also apply when communications meet the definition of marketing and the communication uses or discloses protected health information without a permitted purpose or a valid authorization. Operational controls should prevent protected health information from appearing in email subject lines, preview text, or unprotected links, and should align data handling with the HIPAA Minimum Necessary Rule.
A healthcare organization evaluating Eloqua should treat HIPAA alignment as a scoped implementation tied to the HIPAA add-on, an executed HIPAA Business Associate Agreement, documented configuration standards, and ongoing monitoring of user access, integrations, and campaign assets that handle electronic protected health information.