Comparing HIPAA and GDPR Requirements for Marketing Teams for Dermatology Practices

For dermatology practices, navigating the complex waters of digital advertising while maintaining compliance with both HIPAA and GDPR presents unique challenges. Patient privacy concerns are amplified in dermatology marketing, where before-and-after photos, condition-specific targeting, and sensitive skin condition information create significant compliance risks. Many practices unknowingly violate regulations when tracking conversions from ads for services like acne treatments, Botox, or laser procedures, potentially exposing Protected Health Information (PHI) through standard tracking tools.

The Regulatory Risks Facing Dermatology Marketing Teams

Dermatology practices face specific compliance hurdles that other healthcare specialties might not encounter to the same degree. Here are three significant risks:

Visual Content Compliance Challenges: Dermatology relies heavily on before-and-after imagery, which can inadvertently contain PHI. Meta's pixel can capture user information when these images are viewed, creating a compliance risk even when faces are blurred if other identifiers remain.
Condition-Specific Ad Targeting: Running ads for specific skin conditions like psoriasis or eczema creates risk when Meta's broad targeting associates individual identifiers with medical conditions, potentially creating PHI in ad platforms.
Cross-Device Tracking of Treatment Journeys: Dermatology patient journeys often involve multiple site visits across devices, and standard tracking tools document this journey in ways that could link identifiers to treatment interests.

The Department of Health and Human Services' Office for Civil Rights (OCR) has provided clear guidance on tracking technologies. In their December 2022 bulletin, OCR explicitly stated that tracking technologies that collect and analyze information about users' interactions with a regulated entity's website may result in impermissible disclosures of PHI without patient authorization.

Client-side tracking (like standard Google Analytics or Meta Pixel) sends raw data directly from a user's browser to ad platforms, often including PHI like IP addresses, device IDs, and browsing behavior related to specific treatments. In contrast, server-side tracking routes this data through a secure server first, where PHI can be filtered out before sending conversion data to ad platforms—making it the only HIPAA-compliant approach for dermatology marketing.

Curve's Server-Side Solution for Dermatology Practices

Curve offers a comprehensive solution tailored for dermatology practices struggling with HIPAA and GDPR compliance in their digital marketing. The system operates on two critical levels:

Client-Side PHI Protection: Curve's technology identifies and removes 18+ HIPAA identifiers before any data leaves the patient's browser. For dermatology practices, this means protecting identifiers commonly found in consultation forms where patients describe skin conditions, appointment request details, and even image metadata from uploaded photos of skin concerns.
Server-Side Filtering: Any data that does pass through undergoes a secondary filtering process via Curve's secure servers, ensuring complete PHI removal before sending only compliant conversion data to Google and Meta through their respective APIs.

Implementation for dermatology practices typically follows these steps:

Installation of Curve's tracking code on the practice website and landing pages
Configuration of specific conversion events relevant to dermatology (consultation bookings, treatment interest, etc.)
Connection with practice management software (if applicable) for secure conversion tracking
Setup of custom event parameters that are safe to send to ad platforms
Implementation of GDPR consent mechanisms specific to European patients

This streamlined process typically takes less than a day, compared to the weeks required for custom server-side tracking development, saving dermatology practices both time and significant development costs.

HIPAA-Compliant Optimization Strategies for Dermatology Advertising

Even with HIPAA compliant dermatology marketing infrastructure in place, practices can further optimize their advertising performance while maintaining compliance:

1. Leverage Privacy-Preserving Audience Signals

Rather than building audiences based on specific skin conditions (which creates PHI), utilize broader lifestyle and interest-based signals. For example, target users interested in "skincare" or "beauty treatments" rather than those who've viewed pages about "severe acne treatment" or "psoriasis management."

2. Implement Conversion Value Optimization Without PHI

Curve's integration with Google Enhanced Conversions and Meta CAPI allows dermatology practices to pass different conversion values for different treatment interests without exposing the specific condition. For example, assign higher values to laser treatment conversions versus general consultations without specifying the treatment type to ad platforms.

3. Develop Compliant Lookalike Modeling

Create seed audiences based on general conversion events rather than condition-specific actions. This allows dermatology practices to expand reach while maintaining a firewall between identifiable information and medical interests, remaining compliant with both HIPAA and GDPR targeting restrictions.

By implementing these strategies through Curve's server-side infrastructure, dermatology practices can achieve sophisticated marketing optimization while maintaining strict compliance with both HIPAA and GDPR's requirements around special category data.

Ready to run compliant Google/Meta ads?
Book a HIPAA Strategy Session with Curve

Frequently Asked Questions

Is Google Analytics HIPAA compliant for dermatology practice websites? No, standard Google Analytics is not HIPAA compliant for dermatology practices. It collects IP addresses and user behavior data that could constitute PHI when paired with treatment page views or consultation forms for skin conditions. Google explicitly states in their terms of service that they do not sign Business Associate Agreements for standard Google Analytics. A server-side tracking solution with PHI filtering is required for compliance. How does the GDPR affect dermatology marketing differently than HIPAA? While HIPAA focuses specifically on protecting PHI, the GDPR considers health data as "special category data" requiring explicit consent before processing. For dermatology practices, this means obtaining clear, specific consent before tracking users interested in skin conditions or treatments—even for marketing purposes. Additionally, GDPR provides patients with more extensive rights to access, correct, and delete their data than HIPAA does. Can dermatology practices use retargeting ads under HIPAA and GDPR? Yes, but with significant restrictions. Standard retargeting creates compliance issues by linking identifiable information to healthcare interests. However, with proper server-side tracking that strips PHI before sending conversion data to ad platforms, dermatology practices can implement compliant retargeting. The key is ensuring no identifiable patient information is associated with specific skin conditions or treatments in the ad platform. Under GDPR, explicit consent for marketing is also required before implementing any retargeting.

Sources:

Department of Health and Human Services. "Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates." December 2022.
European Data Protection Board. "Guidelines 05/2020 on consent under Regulation 2016/679." May 2020.
American Academy of Dermatology Association. "Patient Privacy and HIPAA Compliance Guide for Dermatology Practices." 2023.

Mar 15, 2025

‹ The Million-Dollar Risk: Non-Compliant Tracking Pixels for Dermatology Practices

A Primer on HIPAA-Compliant Marketing Technology for Dermatology Practices ›