Twilio SendGrid is not HIPAA compliant for HIPAA Covered Entities or Business Associates because it is not a HIPAA-eligible service, it does not support HIPAA-compliant transmission of electronic protected health information, and Twilio does not sign a HIPAA Business Associate Agreement for SendGrid.
HIPAA requires a written HIPAA Business Associate Agreement when a vendor creates, receives, maintains, or transmits electronic protected health information on behalf of a HIPAA Covered Entity or another Business Associate. Without a HIPAA Business Associate Agreement that covers the specific service in scope, electronic protected health information cannot be placed into the platform, processed by the platform, or sent through the platform as part of a regulated workflow.
Twilio SendGrid’s position is stated directly on its support documentation, including the statement, “Twilio SendGrid does not natively support HIPAA (Health Insurance Portability and Accountability Act) compliant data transmission.” Twilio also states that it is not able to sign Business Associate Agreements for SendGrid, which means SendGrid should not be used for any purpose that involves protected health information.
Email delivery and marketing platforms can inadvertently handle protected health information through contact records, custom fields, tags, segmentation lists, message templates, transactional content, attachments, event registrations, and integrations that synchronize data to customer relationship management tools and data warehouses. Identifiers combined with a healthcare context can constitute protected health information even when clinical details are excluded. Email subject lines, preview text, and link tracking parameters also create disclosure risk because they may be transmitted or logged in systems outside the sender’s control.
Twilio SendGrid can be used by healthcare organizations only for communications and datasets that do not include protected health information and do not link an identifiable person to treatment, payment, or healthcare operations. Marketing communications also require HIPAA Privacy Rule review when a message uses protected health information and meets the definition of marketing, which can trigger authorization requirements depending on the purpose and content.
Twilio SendGrid suggests customer-side encryption or secure download links as risk-reduction measures for sensitive content, but those measures do not make SendGrid a HIPAA-eligible service and do not substitute for a HIPAA Business Associate Agreement.