Governance, Risk & Compliance
A HIPAA compliance consultant in India is almost always working for a business associate rather than a covered entity: an Indian software, analytics, billing or support company handling protected health information for a US healthcare client. The obligations reach you through a business associate agreement, and since the HITECH Act they also reach you directly.
The single most cited failure in HIPAA enforcement is the absence of an accurate, thorough, organisation-wide risk analysis. It is an explicit requirement of the Security Rule, it is the first thing regulators ask for, and it is the foundation on which every other safeguard decision rests, because the Rule deliberately lets you choose safeguards proportionate to your assessed risk.
We run that analysis properly, implement the administrative, physical and technical safeguards it justifies, get the business associate agreements right in both directions, and build the breach notification process the Rule requires. Where the same environment needs broader assurance, SOC 2 and ISO 27001:2022 reuse most of the evidence.
Why you need it
01 / 06Since the HITECH Act and the Omnibus Rule, business associates are directly liable for Security Rule compliance and for breach notification, not merely contractually bound to their covered entity. Enforcement can be brought against you regardless of where you are established.
Business associate agreements are executed early in a commercial relationship and commit you to safeguards, breach reporting timelines, subcontractor flow-down and, frequently, audit rights. Signing one you cannot yet honour is a common and avoidable exposure.
Medical records combine identity, financial and clinical information and cannot be reissued the way a card number can. That makes healthcare a persistent target and makes the consequences of a breach durable.
Any subcontractor of a business associate that creates, receives, maintains or transmits PHI is itself a business associate and needs its own agreement. Cloud providers, support vendors and offshore development partners are all in this chain.
Instrument
02 / 06Access control, encryption, logging and incident response are asked for by several regimes at once. The overlap is work you only do once.
What we deliver
03 / 06The accurate and thorough assessment the Rule requires: where PHI is created, received, maintained and transmitted; the threats and vulnerabilities to it; the likelihood and impact of each; and the current controls. Documented to withstand regulatory scrutiny, and the basis for everything that follows.
Security management process and risk management, assigned security responsibility, workforce security and authorisation, security awareness and training, incident procedures, contingency planning, and periodic evaluation.
Facility access controls, workstation use and security, and device and media controls, including the disposal and re-use procedures that catch out organisations with distributed or home-based staff.
Access control with unique user identification and emergency access, audit controls, integrity controls, person or entity authentication, and transmission security. Addressable specifications are implemented or the alternative documented, never simply skipped.
Reviewing what you have signed with covered entities, and putting agreements in place with every subcontractor that touches PHI. Includes an inventory of where PHI actually flows, which is usually wider than the contract assumes.
The four-factor risk assessment for determining whether an impermissible use or disclosure is a reportable breach, notification procedures and timelines, documentation, and the contractual reporting obligations you owe your covered entity, which are typically far shorter than the regulatory deadline.
How we run it
04 / 06The Security Rule risk analysis: PHI inventory and flows, threats and vulnerabilities, current safeguards, and residual risk rated and documented. Everything else derives from this, and regulators ask for it first.
Weeks 1-4Administrative, physical and technical safeguards proportionate to the assessed risk, with each addressable specification either implemented or its documented alternative recorded.
Months 1-4The policy and procedure set the Rule requires, written to describe what you actually do, with the six-year retention obligation for documentation built into how they are kept.
Months 2-4Security awareness and training for everyone who can reach PHI, with completion recorded. The records are themselves required evidence, and they are frequently what is missing.
Month 4, then periodicallyThe four-factor assessment, notification procedures and timelines to your covered entity and, where you are the covered entity, to individuals and the regulator. Rehearsed rather than merely written.
Month 4Periodic evaluation as the Rule requires, with the risk analysis refreshed on any material change to systems, data flows or the environment.
Annually, and on changeKey benefits
05 / 06A current, documented, organisation-wide risk analysis, the single most commonly missing artefact in HIPAA enforcement actions.
The safeguards, subcontractor agreements and reporting timelines you have committed to are actually in place, in both directions along the chain.
Documented safeguards, training records and breach procedures answer the diligence a covered entity is obliged to perform before sending you PHI.
Tools we use
06 / 06No “latest tech tools”. These are the ones your report will cite, alongside the manual work that a tool cannot do for you.
Regulation
Risk analysis
Technical safeguards
Documentation
Mapping
Why Aphelion
SharedDarshap Nayak, formerly of KPMG, holds a master’s degree in cybersecurity and more than seven years in security operations. Jaimin Somani brings fifteen-plus years of academic and hands-on VAPT. Hemang Desai is an ICT network specialist from Australia. You will meet them, not a logo.
Meet the teamEvery finding arrives with the reproduction steps, the affected asset and the fix, ranked by what it actually reaches in your environment, not by a CVSS number copied from a scanner. You get the report and the raw output, not a summary of a summary.
See how we testAhmedabad and Sharjah, working the same methodology on the same tooling. Indian data-residency requirements and UAE delivery are both ordinary here, and the AphelioNYX AD Pen-Test module runs entirely inside your perimeter when regulation says it must.
The platformInvent a statistic to make a slide land. Publish your name as a client without written permission. Print an award badge nobody awarded. Founded in 2024. We say so, and we attribute experience to the people who have it.
Ask us anythingAcross the globe, and across eight industries. We name a client only with their written permission.
AphelioNYX is SOC 2, ISO and GDPR compliant; attestations are available on request under NDA. We would rather hand you the report than print a badge.
Questions
FAQNext door
RelatedA personalised walkthrough and a free readiness assessment against the frameworks you are actually being asked for. Pick a time that suits you, or write to us. We reply within one business day.