Facebook Signal

Use Case: Demographic data enrichment, audience insights, and behavioral analytics across devices and platforms using Facebook data

Why it matters:

Facebook Signal enhances the data Meta collects by combining on-site tracking with data from Facebook profiles, social interactions, and demographic modeling. It allows businesses to gain deeper insights into website visitors including age, location, interests, and behavior patterns.

On a healthcare website, this enriched data layer can transform standard website interactions into identifiable profiles, especially when a user views condition-specific content or engages with appointment or service pages. When combined with tools like the Facebook Pixel and Conversion Tracking, Signal may contribute to the unlawful disclosure of Protected Health Information (PHI) under HIPAA.

Meta (Facebook) does not offer a Business Associate Agreement (BAA) for Facebook Signal or any of its marketing tools.

What HHS says:

In its official guidance, HHS warns that online tracking technologies including those used for advertising and demographic profiling can collect PHI when tied to an individual’s interaction with a health-related website.

Although a June 2024 court ruling limited the automatic classification of public page visits and IP addresses as PHI, HHS maintains that HIPAA applies when tracking tools can reasonably identify a user’s health-related activity or relationship to care. Because Facebook Signal enhances identification and cross-platform profiling, its use in healthcare contexts poses a significant risk.

Recommendation:

If Facebook Signal is running on your website, particularly on pages related to health services, symptoms, or treatment options, we strongly recommend removing it. This tool collects behavioral and demographic data without HIPAA-aligned controls, and Meta does not sign Business Associate Agreements for Signal or related ad tools.

HIPAA-regulated entities should avoid using any technology that enriches or re-identifies visitor behavior in a way that could suggest a healthcare relationship. For marketing and analytics needs, look for platforms that offer full BAA support and strict data handling policies.