What HIPAA requires of a phone system
A patient discloses protected health information the moment they give a name and a reason for calling. That pulls the answering service inside the regulation as a business associate, and four obligations follow.
A signed BAA is the first and the one people skip. Then encryption of the data in transit and at rest — the audio, the transcript, and anything written into your systems. Then access control with an audit trail, so you can say who read a given record. Then a retention policy with a mechanism behind it, because a stated policy with no deletion job is a statement of intent.
Two things HIPAA does not require, which vendors often imply it does: a SOC 2 report and any particular certification. Those are useful evidence of general security practice, and they are not the regulation.
BAA and who signs it
The covered entity — your practice — signs with each business associate that touches PHI. That includes the answering service, and it includes anyone the answering service passes the data to, which is the chain most evaluations stop short of following. An AI agent has a model provider behind it, and their retention behaviour is part of your exposure whether or not it appears in your contract.
Finn executes BAAs for enterprise engagements that process PHI, per engagement rather than as a blanket clause on every plan, requested through the trust centre. Sign it before any patient data moves. A BAA agreed afterwards does not retroactively cover what already happened.
Worth being clear about where the line sits: the vendor is responsible for the platform’s controls, and you remain responsible for what you use it to do — which calls you make, on what basis, to whom. That division is set out in the consent and legal guidance, and no vendor can take that half from you.
PHI in transcripts and recordings
This is where AI answering services differ materially from human ones, and where the evaluation should concentrate. A human service produces a message: a short, curated note somebody typed. An AI service produces a verbatim transcript of everything the patient said, plus the audio, plus whatever structured data was extracted — several copies of the same PHI in different systems, each with its own retention behaviour.
More data is not automatically worse; a transcript is genuinely more useful and more auditable than a paraphrase. But it is more surface area, and it should be treated that way. Finn encrypts recordings, transcripts and PII with AES-256 at rest and TLS 1.3 in transit by default, and can auto-redact card numbers, SSNs and account IDs from transcripts with custom patterns for anything specific to your organisation — so some categories never persist in readable form at all.
The model layer is the part most reviews miss. Finn does not train on customer data and uses zero-retention model APIs, meaning the audio is not held by the model provider after the call. Ask every vendor that question specifically, because “we don’t train on your data” and “our subprocessors don’t retain it” are two different claims and only one is usually made.
Retention and access control
Access control is only worth what you can prove. Finn writes every data access to an immutable, exportable audit log alongside API calls and configuration changes, which is the artefact that matters in an investigation — the question is never “do you have access controls” but “show me who opened this record”.
On certifications, plainly: Finn holds ISO/IEC 27001:2022 and ISO/IEC 20000-1:2018. Finn is not SOC 2 attested today — an audit is under way with A-LIGN and the report is expected in August 2026. That is stated here for the same reason this page exists: a guide telling you to interrogate vendor claims has no business being vague about its own.
Checklist
Six questions to put to any vendor, Finn included. The answers are more revealing than the compliance page.
- 1
Will you sign a BAA, and at which plan?
If the answer involves an upgrade, that is a price, not a compliance posture. Get the tier in writing.
- 2
What exactly is encrypted, and where are the keys?
'Encrypted' with no object is not an answer. Ask about audio, transcripts, backups and logs separately.
- 3
How long do recordings and transcripts live, and what deletes them?
A retention policy with no deletion mechanism is a statement of intent.
- 4
Do your model providers retain or train on the audio?
Your vendor's subprocessors are your exposure. Ask about the model layer specifically, not just the platform.
- 5
Can you produce an access log for a specific record?
The test is whether they can show you who read a given transcript, not whether logging exists in principle.
- 6
Which certifications do you hold today, and which are in progress?
'In progress' is fine and common. 'Compliant' used to imply an audit nobody has completed is not.
