From Facebook Pixel to BAA-backed: a Spokane dental practice, rebuilt for HIPAA + MHMDA
A small independent dental office came to us with a site built and maintained by a family friend — a setup common across the specialty. The site looked fine. Underneath, it was a compliance liability waiting to happen. Here's what we found and what we rebuilt.
PracticeSingle-location dental
RegionSpokane, WA
RegimeHIPAA + MHMDA
Timeline~6 weeks + ongoing
We never publish the names of clinics we work with — our clients came to us because their site exposed patients, and naming them would defeat the purpose of the engagement. Every identifying detail on this page is either removed or generalized. Technical and regulatory facts are accurate. Read our case-study confidentiality policy.
01 · Before
The site we inherited
Nothing about the site was unusual — which is exactly the problem. This is what a typical small healthcare website in 2025 actually looks like under the hood.
Meta (Facebook) Pixel on every page
Tracking visitors across service pages that described specific procedures — the exact pattern OCR has been fining since the 2022 tracker guidance.
Standard shared hosting, no BAA
The host had unrestricted access to every form submission and every database row. No Business Associate Agreement was ever signed.
General-purpose online booking form
Patient name, phone, and reason-for-visit submitted through a non-HIPAA form service and delivered by plain email.
Maintained by a non-technical family friend
Full CMS admin access from a personal laptop. No 2FA, no access log, no documented handoff procedure.
No Consumer Health Data Privacy Policy
Only a generic template privacy page. MHMDA requires a dedicated, separate notice — and the site didn't have one.
URLs leaking identifiers
Referral-source and patient-name query parameters appearing in URLs, then forwarded to analytics and ad pixels.
02 · Remediation
What we rebuilt (~6 weeks)
The goal wasn't a redesign. The site stayed visually the same. Every piece of infrastructure underneath it changed.
01
Hosting & infrastructure
Migrated to Google Cloud with a signed BAA covering every data flow
Forced TLS 1.3, disabled legacy cipher suites
Content Security Policy headers added to block unauthorized third-party scripts
Session cookies set HttpOnly, Secure, SameSite=Strict
02
Tracking & analytics
Meta Pixel removed entirely — no replacement that touches PHI
Swapped to privacy-preserving analytics (no user-identifying data, no cookies)
Third-party embeds audited — YouTube replaced with privacy-mode embeds, Google Maps swapped for static, no-cookie alternative
Query parameters stripped from URLs; redirect rules added to catch legacy inbound links
03
Forms & PHI flow
Retired the old general-purpose form
Deployed Jotform HIPAA with a signed BAA
Submissions encrypted at rest, routed to a BAA-covered mailbox
Historical submissions exported from the unsecured mail, archived on BAA-covered storage, originals purged
04
Documentation & access
Client-retained legal counsel drafted the HIPAA Notice of Privacy Practices and MHMDA Consumer Health Data Privacy Policy — we integrated both into the site
2FA enforced on every CMS and email account
Admin access revoked from personal devices; LoricaWeb handles site changes on behalf of the practice
Change log maintained — every production edit recorded with author and justification
03 · Ongoing
MHMDA is continuous, not a project
Washington's Consumer Health Data law isn't a one-time fix. A site can be audit-clean today and non-compliant next quarter because a new tracker shipped with a plugin update. This is what the monthly plan actually does for this client.
Dedicated Consumer Health Data Privacy Policy kept current as Washington AG enforcement guidance evolves
Separate consent flow: one consent for collection, a distinct consent for third-party sharing (MHMDA §19.373.030)
Functional data deletion request form — a Washington resident can request deletion, and we process it within the statutory timeline
Consent audit log — every consent event timestamped and stored, retained for enforcement defense
Monthly review of every tracking script and third-party tool on the site — nothing ships without a BAA check
Documented "no-sell" of consumer health data on the policy page, as required under MHMDA
Quarterly re-audit of the site against updated HIPAA + MHMDA guidance
Staff protocol document for handling MHMDA consumer rights requests within the required timeline
04 · Outcome
Where the practice stands now
BAA coverage end-to-end
Hosting, forms, analytics, email — every vendor that could touch PHI has a signed BAA on file.
MHMDA-ready workflow
Consent flow, deletion request handling, and Consumer Health Data Privacy Policy operational and maintained.
No third-party PHI leaks
Every tracking script and embed passes a monthly review. Nothing new reaches the site without a BAA check.
Owner off the hook for a stack they don't run
The practice owner stopped being the person personally accountable for a web infrastructure they never signed up to manage.
What this looks like from the patient's side: nothing changed. The site looks the same.
The difference is that every form, tracker, and cookie on that page has a BAA — or doesn't exist at all.
Your practice probably looks a lot like the 'before' here.
Get a free audit and find out which of these violations are on your site right now. No commitment — just a prioritized PDF you can act on.