HIPAA applies to all health data regardless of what you do with it. It’s one of the few things similar to ITAR that you cannot put off for later. The fines for

HIPAA applies to all health data regardless of what you do with it. It’s one of the few things similar to ITAR that you cannot put off for later. The fines for not complying can be staggering ($50k-$1.5m). I highly recommend talking to someone who knows HIPAA well.