DRAFT: HIPAA Identity Pattern

Purpose

The HIPAA Identity Pattern defines the approved implementation model for authentication, authorization, privileged access, service identities, and identity governance for HIPAA workloads hosted in University-managed Azure environments.

This pattern provides a consistent identity architecture that supports security, operational management, auditability, and compliance requirements for workloads that create, store, process, transmit, or provide access to Protected Health Information (PHI).

Use Cases

This pattern applies when:

  • Hosting applications that contain PHI
  • Hosting databases that contain PHI
  • Deploying HIPAA landing zones
  • Deploying HIPAA subscriptions
  • Implementing administrative access to HIPAA resources
  • Implementing service-to-service authentication

This pattern does not apply to:

  • Non-regulated development environments
  • Sandbox environments without PHI
  • Non-regulated workloads

Design Principles

Centralized Identity

HIPAA workloads use approved enterprise identity services as the authoritative identity provider.

Workloads should not implement independent identity systems when approved enterprise identity capabilities satisfy business requirements.

Role-Based Access Control

Access should be assigned through roles and groups rather than directly to individual users whenever practical.

Least Privilege

Users, administrators, applications, and automation receive only the permissions necessary to perform approved business functions.

Identity Lifecycle Management

Identity creation, modification, and removal should align with approved organizational lifecycle processes.

Auditable Access

Authentication events, authorization changes, and administrative activities must be observable through approved monitoring and auditing services.

Logical Architecture

User
    ↓
Enterprise Identity Platform
    ↓
Authentication
    ↓
Authorization
    ↓
HIPAA Workload

Application
    ↓
Application Identity
    ↓
HIPAA Resource

Automation
    ↓
Service Identity
    ↓
HIPAA Resource

Identity Types

Workforce Identities

Used by faculty, staff, researchers, administrators, operators, and support personnel.

Responsibilities include:

  • Application access
  • Administrative access
  • Operational access
  • Support activities

Privileged Identities

Used to administer HIPAA resources and services.

Examples include:

  • Cloud administrators
  • Platform administrators
  • Database administrators
  • Service administrators

Application Identities

Used by applications requiring access to other services.

Examples include:

  • API-to-API communication
  • Application-to-database access
  • Application-to-service access

Automation Identities

Used by automation, deployment pipelines, orchestration platforms, and scheduled processes.

Examples include:

  • Infrastructure deployment
  • Operational automation
  • Data movement
  • Integration workflows

Access Model

Authentication

Authentication is performed through approved enterprise authentication services.

Workloads should leverage enterprise identity services rather than maintaining local credentials whenever practical.

Authorization

Authorization should be assigned using approved role-based access models.

Group-based assignment should be used whenever possible.

Platform Access

Administrative access should be separated from standard user access.

Administrative access must follow approved privileged access processes.

Identity Boundaries

HIPAA Workload Boundary

HIPAA workloads remain isolated within approved HIPAA subscriptions and hosting patterns.

Enterprise Identity Boundary

Approved enterprise identity services may operate as shared enterprise services supporting HIPAA workloads.

Identity services do not need to be duplicated within every HIPAA subscription provided approved governance and security controls are maintained.

Identity Governance

Provisioning

Access is granted through approved onboarding and access management processes.

Modification

Identity changes should follow approved governance and change processes.

Removal

Access should be removed when business need no longer exists.

Monitoring and Auditability

Identity activities should be observable through approved monitoring solutions.

Monitoring should support:

  • Authentication activity review
  • Access review activities
  • Administrative activity review
  • Security investigations
  • Compliance activities

Operational Responsibilities

Platform Team

  • Identity architecture
  • Identity pattern management
  • Platform identity services

Security Team

  • Identity governance requirements
  • Security reviews
  • Security investigations

Workload Owner

  • Application authorization design
  • Business role definitions
  • Access approval processes

Automation Pattern

Identity configuration should be deployed through approved platform automation whenever practical.

Typical automation areas include:

  • Role assignments
  • Identity integration
  • Workload onboarding
  • Service identity deployment
  • Landing zone deployment

Reference Architecture Outcomes

A workload implementing this pattern should provide:

  • Centralized authentication
  • Role-based authorization
  • Privileged access separation
  • Identity auditability
  • Identity lifecycle governance
  • Consistent identity implementation across HIPAA workloads

Reference Architecture Capabilities

The HIPAA Identity Pattern provides the following identity capabilities for regulated workloads.

Authentication

Provides:

  • Workforce authentication
  • Administrative authentication
  • Application authentication
  • Service authentication
  • Federated authentication

Authorization

Provides:

  • Role-based access control
  • Group-based authorization
  • Least privilege enforcement
  • Separation of duties
  • Granular access management

Privileged Access Management

Provides:

  • Administrative access governance
  • Elevated access controls
  • Privileged role management
  • Administrative access separation
  • Time-bound privileged access

Workload Identity Management

Provides:

  • Application identities
  • Service identities
  • Non-human authentication
  • Service-to-service trust relationships
  • Automated workload authentication

Identity Governance

Provides:

  • Identity provisioning
  • Identity modification
  • Identity removal
  • Access review processes
  • Lifecycle management

Audit and Accountability

Provides:

  • Authentication auditing
  • Authorization auditing
  • Administrative activity auditing
  • Security investigation support
  • Compliance reporting support

Platform Integration

Provides:

  • Integration with enterprise identity services
  • Integration with enterprise monitoring services
  • Integration with enterprise governance processes
  • Integration with HIPAA hosting services
  • Integration with approved automation platforms

Reference Architecture Services

The HIPAA Identity Pattern is implemented through the following logical identity services.

Identity Provider Service

Responsibilities:

  • Authenticate users
  • Authenticate applications
  • Establish identity trust
  • Provide authoritative identity information

Authorization Service

Responsibilities:

  • Evaluate access permissions
  • Enforce authorization decisions
  • Manage role assignments
  • Manage group memberships

Privileged Access Service

Responsibilities:

  • Govern administrative access
  • Control elevated permissions
  • Support privileged access workflows
  • Support administrative accountability

Workload Identity Service

Responsibilities:

  • Provide application identities
  • Provide service identities
  • Support service authentication
  • Eliminate dependency on shared credentials

Identity Governance Service

Responsibilities:

  • Provision identities
  • Modify identities
  • Remove identities
  • Support access reviews
  • Support identity lifecycle management

Identity Audit Service

Responsibilities:

  • Collect authentication events
  • Collect authorization events
  • Collect administrative activity
  • Support investigations
  • Support compliance activities
Print Article