Row Zero is the best spreadsheet for big data. Try for free →

Spreadsheet HIPAA Compliance Checklist

2025-09-16 // Mark Tressler

Row Zero is a HIPAA compliant spreadsheet application that helps solve the security and performance issues of typical spreadsheet usage. In this guide, we'll outline some of the key components of spreadsheet HIPAA compliance. We'll also show how Row Zero helps organizations maintain HIPAA compliance while letting teams securely work in spreadsheets. You can try Row Zero for free or schedule a demo to explore our enterprise features.

Explore Row Zero

Are your spreadsheets HIPAA compliant?

Below we outline the key components of HIPAA compliance for spreadsheets, but first here are some higher level questions to ask that can serve as an initial spreadsheet HIPAA compliance checklist:

  1. Do you use files (e.g. XLSX files)? Files are significantly riskier and more complicated to maintain HIPAA compliance. Spreadsheets should be accessible only in a secure portal where data is locked and cannot be exported. Ideally the user comes to the data, not the data comes to the user. secure HIPAA compliant spreadsheets

  2. How does customer data get into spreadsheets? Ideally you want a direct, secure connection between your data source and your spreadsheets, without any file downloads or transfers.

  3. Who COULD get access to the spreadsheet? Can spreadsheets be copied, shared, emailed, slacked, or downloaded? You need to do more than just restrict access to the spreadsheet. You also have to restrict sharing and copying of the spreadsheet.

  4. Did you sign a BAA with the spreadsheet software provider? To be HIPAA compliant, you have to sign a BAA with the provider of the spreadsheet software, along with any other tools used with your spreadsheets (e.g. Excel add-ons, data connectors, storage, etc.)

  5. Can employees copy and paste patient data? Copy and paste is a simple, yet common way for patient data to leak into non-secure software and communication channels.

  6. How do you handle when customer data is entered directly into a spreadsheet? This is often overlooked, but is a common way for patient data to enter a spreadsheet and not be covered by centralized audit controls and logging.

These are just a few of the common ways that organizations may violate HIPAA compliance. Below we outline the key components of HIPAA compliance for spreadsheets.

Key Components of HIPAA Compliance for Spreadsheets

The core components of HIPAA are the Privacy Rule, which protects Patient Health Information (PHI); the Security Rule, which sets guidelines for electronic PHI (ePHI), and the Breach Notification Rule, which requires notification after a PHI breach. Under the HIPAA Security Rule, there are three main pillars - Administrative Safeguards, Physical Safeguards, and Technical Safeguards. Below we list some of the key components of spreadsheet HIPAA compliance related to these three pillars. When using a HIPAA compliant spreadsheet like Row Zero, you can leverage advanced security features to help establish and maintain HIPAA compliance. However, as will all tools, proper setup, training, and enforcement is necessary to ensure HIPAA compliance. And it's always important to have a legal team review your particular set up, workflows, and use cases to ensure you maintain HIPAA compliance across your spreadsheets.

  1. Access Controls (Technical Safeguard)
    • Limit access to authorized users only. Spreadsheets should enforce row level security (RLS) and role-based access controls (RBAC).
    • Use strong authentication (e.g., SSO, multi-factor authentication, device-based trust).
    • Restrict sharing, downloading, and data exports
  2. Integrity Controls (Technical Safeguard)
    • Have users access data from a centralized, governed data source like a data warehouse.
    • Ensure PHI is not improperly altered or deleted.
    • Use data validation wherever data is entered in your system to reduce entry errors.
  3. Transmission and Storage Security (Technical and Physical Safeguard)
    • Enforce encryption in transit (e.g., HTTPS, secure connectors) between your data source and your spreadsheets.
    • Store spreadsheets in HIPAA-compliant cloud platforms with encrypted-at-rest storage.
    • Avoid emailing spreadsheets with PHI
    • Avoid saving local files on unprotected devices.
    • Restrict downloads and data exports
    • Restrict sharing outside the org's workspace and outside the application.
  4. Audit Controls & Activity Logging (Technical Safeguard)
    • Ensure change history/versioning is enabled (e.g. version history in Row Zero and Google Sheets or Excel 365 audit logs).
    • Monitor and periodically review activity logs and access controls.
  5. Device & Session Management (Physical Safeguard)
    • Require secure, enterprise-managed devices.
    • Use session timeouts or auto-logout features.
    • Prevent access from unauthorized or personal devices.
  6. Business Associate Agreements (BAA) (Administrative Safeguard)
    • Ensure spreadsheet platforms (e.g., Google, Microsoft, Row Zero) have signed BAAs with your organization.
    • Verify that third-party services are also under a BAA. This includes spreadsheet add-ons and any tools that store or transfer spreadsheet data.
  7. Training & Workforce Oversight (Administrative Safeguard)
    • Train users on how to handle PHI in spreadsheets.
    • Include specific rules and examples of spreadsheets in HIPAA training (e.g., never copy PHI to a personal sheet).
    • Maintain and document HIPAA compliance policies and procedures.
  8. Data Minimization & De-identification (Best Practice)
    • Only include PHI necessary for the task at hand.
    • De-identify data when possible (e.g., no names or SSNs).
    • Use pseudonyms, email hashes, or record numbers instead of real identifiers.
  9. Retention, Archiving, and Disposal (Administrative and Technical)
    • Define how long PHI-containing spreadsheets are kept.
    • Establish an automated process for deleting spreadsheets after their useful life (for example, a set number of days after last opened).
  10. Spreadsheet-specific focus
    In all scenarios, it's important to put a specific emphasis on spreadsheets for maintaining HIPAA compliance. Spreadsheets have a tendency to propagate data since they are so easily duplicated, downloaded, and shared. In most organizations, spreadsheets are the most common data tool. The ubiquity of spreadsheets and the wide variety of ways that people use spreadsheets mean they often cover a very large surface area for data governance and security. Without very robust protocols, typical spreadsheet usage can violate HIPAA compliance and it only takes one user and one spreadsheet for PHI to leak to an unauthorized viewer, which is why choosing the right spreadsheet is critical.

HIPAA Identifiers Common in Spreadsheets

HIPAA Identifiers are pieces of information that could be used to identify an individual and count as Protected Heath Information (PHI). It's very important to be extra cautious when working with any of the following data in a spreadsheet or any other tool:

  1. Full name
  2. Email address
  3. Phone number
  4. Address
  5. Birth date
  6. Medical record number (MRN)
  7. Health plan beneficiary number
  8. IP address
  9. Any notes fields that may contain identifiable information

If possible, try not to use PHI in spreadsheets. You should only use the PHI necessary for the specific task at hand and you should de-identify data or use pseudonyms when possible. Ensure any spreadsheets containing PHI are not downloaded, copied, or shared unless there are specific secure protocols for doing so. Spreadsheets with PHI should also be deleted after their useful life, ideally automatically to ensure compliance.

How Row Zero helps organizations maintain HIPAA compliance

Row Zero is a HIPAA compliant spreadsheet application that is specifically built for security and big data performance. Row Zero locks spreadsheets in a secure cloud portal and organizations can choose to restrict data export, sharing, and copy/paste. There are no files. Spreadsheets are only accessible via secure login (e.g. SSO) and row-level security is enforced from the data warehouse, so users can only see data they are authorized to see. Row Zero also supports 1000x bigger data than legacy spreadsheets, so teams can easily work with large datasets in a secure spreadsheet.

Conclusion

Without proactive security measures, typical spreadsheet usage can violate HIPAA compliance. For teams that work with sensitive data or large datasets, Row Zero is a secure alternative to Excel and Google Sheets that is HIPAA compliant. Row Zero makes it easy to securely connect spreadsheets to your source data and has advanced security features that help improve data governance and security across your spreadsheets and maintain HIPAA compliance. You can try Row Zero for free or compare plans here.

Explore Row Zero

FAQs