HIPAA Privacy Officer vs Security Officer
The Privacy Officer is responsible for the Privacy Rule. The Security Officer is responsible for the Security Rule. Both roles are required and can be held by the same individual.
Last reviewed May 24, 2026
Side by side
Privacy Officer
Designated individual responsible for the development and implementation of the policies and procedures of the covered entity required by the HIPAA Privacy Rule.
45 CFR 164.530(a)- Required by 45 CFR 164.530(a)(1).
- Handles patient rights requests, complaints, and Privacy Rule training.
Security Officer
Designated individual responsible for the development and implementation of the policies and procedures required by the HIPAA Security Rule.
45 CFR 164.308(a)(2)- Required by 45 CFR 164.308(a)(2).
- Owns the Security Risk Analysis, technical safeguards, workforce access management.
When to use Privacy Officer
- Receiving a patient right-of-access request, processing a complaint, conducting Privacy Rule training.
When to use Security Officer
- Conducting the annual Security Risk Analysis, evaluating a vendor's safeguards, responding to a security incident.
Common mistakes
- Designating only one officer without documenting that the role covers both Privacy and Security.
- Treating the Security Officer as an IT-only function — Security Rule covers administrative and physical safeguards too.
- Failing to keep the designation document up to date when staff turn over.
Sources
- 45 CFR 164.530 (Privacy administrative requirements)https://www.ecfr.gov/current/title-45/section-164.530
- 45 CFR 164.308 (Security administrative safeguards)https://www.ecfr.gov/current/title-45/section-164.308
Related
Document the designations in the SRA readiness check
Open sra studio →D3rx is a healthcare-billing and compliance research aid maintained by D3rx Inc. Articles are drafted by an LLM (Anthropic Claude) against primary HHS, OCR, CMS, eCFR, NIST, and state-regulator publications, and reviewed for restraint and source fidelity by the D3rx team.
Reviewer status: a named credentialed reviewer (CHC, CHPC, or healthcare attorney) is being engaged. Until that engagement is finalized, this page does not claim credentialed review.
This comparison is a research aid for billing and compliance staff. It does not provide legal, medical, or financial advice and does not replace counsel. References cited link to primary sources at CMS, HHS, OCR, eCFR, NIST, and the relevant payer or state regulator. Last reviewed May 24, 2026.