Do we need a Privacy Officer?
Yes — someone must own HIPAA privacy for your organization. At a small practice, that can be a part-time role.
TL;DR
HIPAA requires a privacy official responsible for policies, training coordination, and complaints. In small practices, the practice manager often wears this hat alongside other duties.
Updated 2026-04-21
HIPAA expects every covered entity to have a Privacy Official (sometimes called a privacy officer). That person is the named leader for privacy policies, workforce training, patient rights processes, and complaint handling.
Does it have to be a full-time job?
No. Many solo and small practices combine the role with office management. What matters is that someone is accountable, documented, and reachable when staff have questions or incidents happen.
What do they actually do?
Day-to-day, a privacy officer often:
- Keeps Notices of Privacy Practices up to date and available.
- Makes sure training happens for new hires and refreshers.
- Reviews vendor BAAs and tracks where data lives.
- Leads investigations when something goes wrong.
- Serves as the contact point for patient complaints about privacy.
How do we "designate" someone?
Put it in writing—job description addendum, policy page, or organizational chart note. Train that person enough that they know when to call counsel or a HIPAA consultant.
Pair with security leadership
Larger organizations often split privacy and security roles. Small sites may combine them, but still document who owns technical safeguards like backups and access reviews.
Keep reading
Next in your reading path → Do we need to sign anything? Business Associate Agreements explained simplyNot legal advice. Educational overview only; consult qualified counsel for your situation.