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Hosting & Infrastructure

Shared Responsibility Model

The split of security duties between a cloud provider and its customer; the cloud secures the infrastructure, the customer secures what runs on it.

The shared responsibility model is the split of security duties between a cloud provider and its customer. The provider secures the physical data centers, hardware, and core services. The customer secures everything built on top: operating systems, encryption settings, access rules, and logging.

Under HIPAA, this split means a signed BAA with AWS, Azure, or Google Cloud is necessary but not sufficient. The safeguards at 45 CFR § 164.312 that fall on the customer side must still be configured, which is where most audit failures happen. See our HIPAA cloud hosting guide for how the split works in practice. A managed alternative, where the host configures that customer side under its own BAA, is a HIPAA cloud hosting service.

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