HIPAA and GDPR are the two most consequential data protection frameworks any healthcare or technology organisation is likely to encounter. They share a common purpose, protecting sensitive personal data, but they differ significantly in scope, enforcement mechanisms, and compliance obligations. For organisations operating across the Atlantic, understanding where they align, where they clash, and how to satisfy both simultaneously is not optional. It is a legal necessity. What Is HIPAA? The Health Insurance Portability and Accountability Act was enacted by the U.S. Congress in 1996. Its original purpose was to modernise the flow of healthcare information and ensure the portability of health insurance coverage. Over time, it became primarily known for its data protection requirements, administered by the U.S. Department of Health and Human Services (HHS) and enforced by the Office for Civil Rights (OCR). HIPAA is built around three core rules. The Privacy Rule governs how Protected Health Information (PHI) may be used and disclosed. The Security Rule sets standards for safeguarding electronic PHI (ePHI). The Breach Notification Rule establishes mandatory reporting timelines when PHI is compromised. Who Needs to Be HIPAA Compliant? HIPAA applies to covered entities, healthcare providers, health plans, and healthcare clearinghouses, and to their business