Processing of HIPAA Data in the Snowflake Service is prohibited unless a separate Business Associate Agreement has been executed. Without a BAA, Snowflake expressly disclaims all liability for HIPAA Data regardless of the circumstances or applicable law.
This analysis describes what Snowflake's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision conditions all HIPAA Data processing on the prior execution of a BAA, and states that Snowflake bears no liability for HIPAA Data absent such agreement. The disclaimer of liability is asserted to apply notwithstanding HIPAA itself or similar laws, though the enforceability of a complete statutory liability disclaimer in the context of HIPAA may be subject to regulatory and legal evaluation.
Under this clause, healthcare organizations or any Customer processing protected health information must execute a separate BAA with Snowflake before using the Service for that purpose. Absent a BAA, the agreement states that Snowflake bears no liability for HIPAA Data, and any HIPAA-regulated processing conducted without a BAA is a Customer responsibility and a breach of the agreement's use obligations.
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Compare across platforms →"Customer agrees not to process any HIPAA Data in the Service unless Customer has entered into a BAA with Snowflake. Unless a BAA is in place, Snowflake will have no liability under this Agreement for HIPAA Data, notwithstanding anything to the contrary in this Agreement or in HIPAA or any similar federal or state laws, rules or regulations.Excerpt from Snowflake's Terms of Service
(1) REGULATORY LANDSCAPE: This provision directly implicates HIPAA and its implementing regulations, enforced by the HHS Office for Civil Rights.
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This provision conditions all HIPAA Data processing on the prior execution of a BAA, and states that Snowflake bears no liability for HIPAA Data absent such agreement. The disclaimer of liability is asserted to apply notwithstanding HIPAA itself or similar laws, though the enforceability of a complete statutory liability disclaimer in the context of HIPAA may be subject to regulatory …
Under this clause, healthcare organizations or any Customer processing protected health information must execute a separate BAA with Snowflake before using the Service for that purpose. Absent a BAA, the agreement states that Snowflake bears no liability for HIPAA Data, and any HIPAA-regulated processing conducted without a BAA is a Customer responsibility and a breach of the agreement's use obligations.
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