The practical question is not whether the site looks like a healthcare website. For a psychology practice subject to HIPAA, review the specific feature and the complete data path. A public article or service description is different from an identifiable submission made while someone is seeking care. The practice should document where information is created, received, maintained, or transmitted before deciding which privacy and security controls apply.
Data-flow review for website features that can handle PHI:
- Contact forms: inspect every field, hidden field, notification email, database, log, CRM handoff, and analytics event when symptoms, diagnoses, treatment history, reasons for seeking care, or other identifiable health context may be submitted.
- Scheduling: trace whether an identifiable person is connected with appointment reasons, provider selection, care context, or other information that can make the booking data sensitive.
- Patient portals: document records access, secure messaging, authentication, vendor responsibilities, storage, and integrations rather than assuming the portal label answers the compliance question.
- Intake: map identifiable health, insurance, demographic, and communication data from collection through storage, staff access, export, backup, and deletion.
Public content normally needs a different analysis:
- Educational articles do not become patient information merely because they discuss mental health.
- Descriptions of services and credentials should still be reviewed for accuracy, advertising rules, and professional scope.
- A Business Profile listing should not reveal patient information and should represent the practice, practitioners, locations, and credentials accurately.
Do not classify a submission by one field in isolation. Name, email, phone number, IP address, page context, appointment details, health information, tracking parameters, and downstream systems can change the analysis when considered together. A form described as general contact can still require a HIPAA review if its actual use connects an identifiable person with care-seeking information.
Controls to evaluate when a site handles ePHI:
- Protection for data in transit and appropriate downstream storage
- A BAA with a vendor when that vendor creates, receives, maintains, or transmits PHI on the practice's behalf
- Access controls, workforce procedures, risk analysis, and system activity review appropriate to the environment
- Documented incident and breach-response procedures that include website and integration data
Use this section to structure an internal review, not as a legal determination. Qualified privacy counsel should evaluate the practice's actual systems, contracts, and obligations.