HIPAA’s 2025 Security Rule Updates: What They Mean for GA4 and GTM

If you’re in healthcare marketing and still using Google Analytics 4 (GA4) or Google Tag Manager (GTM) without thinking twice, it’s time to take a closer look. The HIPAA Security Rule update proposed in early 2025 is more than just another regulatory tweak.

It’s a wake-up call for any organization handling Protected Health Information (PHI), especially if you rely on third-party tools that haven’t kept up with evolving privacy and security standards.

For years, many marketers assumed that avoiding obvious PHI fields like names or medical records was enough. But the HIPAA Security Rule updates introduced by the Department of Health and Human Services (HHS) go much deeper. They now require stricter cybersecurity practices, clearer responsibilities for Business Associates, and far more accountability for how healthcare data flows through your digital infrastructure, including analytics tools.

So, what do these changes actually mean for GA4 and GTM? And how can you keep growing without crossing compliance lines? Let’s break it down.

The Proposed 2025 HIPAA Security Rule: What’s Changing?

The Security Rule is one of the key components of the Health Insurance Portability and Accountability Act (HIPAA). It sets standards for keeping Protected Health Information (ePHI) safe through technical and administrative safeguards.

The HIPAA Security Rule update proposed in January 2025 is designed to address growing cybersecurity threats in healthcare. As more providers, marketers, and vendors rely on digital tools to collect and process data, the government is stepping in with clearer, stricter standards.

If finalized, the proposed updates will require:

• Multi-Factor Authentication (MFA) is now mandatory for any system that accesses or stores ePHI. This includes marketing platforms and third-party tools that handle data tied to healthcare services.
• Encryption isn’t optional anymore. Covered entities and their Business Associates must use strong encryption methods both at rest and in transit to protect sensitive data.
• Regular vulnerability scans and annual penetration testing are now part of the game. These security checks must be documented and acted upon as part of your organization’s risk management process.
• Asset inventory requirements have been expanded. Any system, tool, or vendor that touches PHI must be tracked and reviewed on an ongoing basis.
• Business Associates have more responsibility. If you’re using external partners for your analytics, advertising, or hosting, they’ll now be expected to meet the same technical safeguards, and you’ll need written proof.

The purpose of these HIPAA Security Rule updates is clear: bring healthcare cybersecurity into the modern era and reduce the risk of breaches by tightening every link in the data chain.

Why GA4 and GTM Are in the Hot Seat

Healthcare marketers widely use GA4 and GTM to track performance, optimize content, and improve user experience. But the HIPAA Security Rule update raises important concerns about whether these tools are safe to use without proper safeguards.

Google does not sign Business Associate Agreements (BAAs) for those tools, which already puts you on shaky ground. The risks multiply when you consider how they work under the hood.

Here’s what makes GA4 and GTM risky in light of the HIPAA Security Rule updates:

• They can collect PHI without warning: Misconfigured tags or URL parameters may expose health-related data like conditions, treatments, or appointment details.
• No built-in encryption or access controls: The HIPAA Security Rule updates require technical safeguards that GA4 and GTM simply don’t offer by default.
• They lack required audit and logging features: You can’t fully monitor or control who accesses the data or how it’s shared.
• IP addresses and location data create risk: Even anonymous-looking data can qualify as PHI when linked to user behaviour on healthcare websites.

The HIPAA Security Rule update makes it clear that these tools must be reevaluated. If they’re not secured, limited, or replaced with HIPAA-compliant alternatives, you may need to secure, restrict, or replace them with compliant alternatives..

What to Fix Before It’s Too Late

The HIPAA Security Rule updates aren’t just suggestions. They’re a clear signal that healthcare organizations and their partners must take a more active role in securing data. If your marketing stack includes tools like GA4 and GTM, it’s time to act.

Here’s what you should prioritize:

• Audit your entire tracking setup: Review all GA4 and GTM configurations to identify any tags, triggers, or data layers that could collect PHI (intentionally or not).
• Remove or block PHI from data layers: Avoid passing any personal or health-related identifiers through URLs, forms, or custom dimensions.
• Enable IP anonymization and disable user-ID features: These settings won’t make GA4 compliant on their own, but they reduce risk when used correctly.
• Document everything: The HIPAA Security Rule update requires formal risk assessments. Keep clear records of audits, mitigation steps, and tool configurations.
• Evaluate your Business Associates: If a third party manages your analytics or paid ads, make sure they understand the new requirements and are willing to sign a BAA.

The HIPAA Security Rule updates are about accountability. That starts with understanding where your risks are and taking the necessary steps to fix them.

What Happens If You Don’t?

The HIPAA Security Rule update raises the stakes for anyone handling electronic protected health information. Overlooking these changes (especially in your marketing tools) can lead to serious consequences.

With stricter enforcement in place, tools that collect PHI but lack proper safeguards could result in steep multi-million-dollar fines. Breaches are also more likely if platforms like GA4 and GTM aren’t encrypted, audited, or tightly controlled. And if a violation occurs, regulators will look closely at your setup.

Beyond legal risk, there’s the matter of trust. Patients expect their data to be protected. A privacy slip tied to your marketing stack can damage your reputation fast. And if your partners aren’t following the HIPAA Security Rule updates, the responsibility still falls on you.

What’s changed with the HIPAA Security Rule update is the expectation. Marketing tools are now held to the same standard as clinical systems.

The good news? You can still use powerful analytics tools without crossing the line.

Compliance Doesn’t Have to Kill Your Marketing

The HIPAA Security Rule updates are setting a new standard, and marketers can’t afford to ignore them. GA4 and GTM may be powerful, but without the right safeguards, they fall short of what HIPAA now expects.

That’s where HIPALYTICS helps, turning GA4 and GTM into HIPAA-compliant tools you can trust.

We make GA4 and GTM HIPAA-compliant by filtering out PHI, storing data securely on US-based servers, and signing a Business Associate Agreement to protect your organization. You get the insights you need, with none of the compliance risks.

One solution, full protection. Let’s make your analytics work for you, the right way.