Can I Use Microsoft Windows 11 Home in a HIPAA Environment?

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Windows 11 Home, Windows 11 Pro, and Windows 11 Enterprise contain different features. Of the three products, though, only Windows 11 Pro and Windows 11 Enterprise should be used in an environment where PHI is created, maintained, received, and/or transmitted. 

Why Should Windows 11 Pro or Enterprise be Used Instead of Windows 11 Home?
Windows 11 Pro and Enterprise provide Bitlocker encryption, but Windows 11 Home does not. Bitlocker is a preferred method of encryption in a HIPAA environment. With BitLocker, a user can encrypt a single drive or all drives. With Bitlocker, the user is given a series of management tools to protect their data. Bitlocker encryption is full-device encryption with management controls.

The HIPAA Security Rule contains an addressable encryption standard that requires covered entities and business associates to “Implement a mechanism to encrypt electronic protected health information whenever deemed appropriate.”

Encrypting ePHI at rest (stored ePHI) and ePHI in transit (ePHI being transmitted) with full-device encryption is a measure that an organization should implement if reasonable and appropriate to do so.

If an organization concludes that encryption using Bitlocker is genuinely not feasible, or is impossible, the organization must document why this is the case, and must implement equivalent safeguards to protect devices. Equivalent safeguards ("compensating controls") may include access controls, including unique user ID and password authentication and user profiles; hardening of systems; physical security to facilities and workstations, including appropriate device and media controls; strong passwords; system security auditing and logging and monitoring of audit reports/logs; correct configuration of applications to use secure protocols; automatic logoff and/or screen lock; secure remote access; and correctly configured firewalls. 

There are a number of additional reasons why Windows 11 Home and Windows 11 for Education should not be used in a HIPAA environment, beyond the matter of encryption. Windows 11 Home is not designed for business use, which means its use when working with sensitive data is especially problematic. 

In the Home version of ALL Microsoft operating systems since Windows 7, telemetry data is shared with Microsoft. With Windows 10 and Windows 11, the Cortana feature also collects and in some cases shares data as someone uses the system. This feature cannot be disabled in either case in a Home Operating System (OS). A user may permanently block the feature in Pro Enterprise, but cannot even see what data is being captured in Home.

Windows 11 Pro, AI, and HIPAA 
Microsoft Copilot Studio is covered under the Health Insurance Portability and Accountability Act (HIPAA) Business Associate Agreement (BAA).

Users can create copilots that handle protected health information when your organization is bound by HIPAA, as in the following scenarios where the copilot can:

• Ask individuals to provide their health information (blood pressure, weight, and so on).
• Capture health information and personally identifying information, such as the customer's IP address or email address.