Twilio can be HIPAA compliant when a HIPAA Covered Entity or Business Associate executes Twilio’s Business Associate Agreement or Business Associate Addendum for Twilio HIPAA-eligible products and then designs, configures, and operates the implementation so that electronic protected health information is created, received, maintained, and transmitted under controls that meet HIPAA Privacy Rule, HIPAA Security Rule, and HIPAA Breach Notification Rule requirements.
HIPAA compliance for a communications platform depends on contract scope and technical and administrative controls. A vendor that creates, receives, maintains, or transmits electronic protected health information on behalf of a regulated organization operates as a business associate, and a HIPAA Business Associate Agreement must define permitted uses and disclosures, required safeguards, breach reporting, and subcontractor obligations. Twilio indicates that it will sign a Business Associate Agreement or Business Associate Addendum for customers using Twilio HIPAA-eligible products and services, which establishes a contractual basis for regulated use when the deployed services are covered by that agreement.
HIPAA eligibility is product-specific and use-case-specific. Some Twilio services can be placed under a Business Associate Agreement for workflows that include protected health information, while other Twilio-owned services are not positioned for protected health information transmission. Twilio SendGrid is commonly evaluated alongside Twilio’s communications APIs, but SendGrid is not a HIPAA-eligible service for protected health information and is not offered with a Business Associate Agreement for email transmission of protected health information. That separation matters for architecture decisions that combine SMS, voice, chat, email delivery, customer data platforms, and integrations.
Operational controls determine whether protected health information is exposed through message content, identifiers, metadata, logs, or downstream systems. Implementation planning should restrict protected health information from appearing in SMS bodies, voice transcripts, chat messages, email subject lines, tracking parameters, and support tickets unless the workflow and the service are within the Business Associate Agreement scope and the organization has documented safeguards. Access controls, audit controls, authentication, transmission security, retention limits, integration governance, and incident response procedures should be defined for each channel and each data flow that touches protected health information.
Twilio can support HIPAA-aligned communications when the organization uses only covered HIPAA-eligible services under a signed Business Associate Agreement and enforces configuration and workforce controls that prevent unauthorized use or disclosure of protected health information.