Signal Loom Legal Pre-Flight™ · Version 1.0 · 2026-04-16
Classification: Confidential · Attorney-Client Privilege · Work Product
This document defines three deployment models for Signal Loom Legal Pre-Flight. Each model represents a different trade-off between HIPAA compliance obligations, infrastructure complexity, and security posture. The model selected depends on the firm's existing infrastructure and risk tolerance.
Data never leaves the attorney's infrastructure. No PHI on Signal Loom systems.
No BAA RequiredBest for: Firms with existing HIPAA-compliant infrastructure
Signal Loom's HIPAA-configured cloud. Full SaaS. BAA required and provided.
BAA RequiredBest for: Firms wanting managed infrastructure with HIPAA compliance
Client-side encryption. Signal Loom cannot read data in any form.
No BAA RequiredBest for: Highest security requirements, government-adjacent clients
Current: AES-256 field-level encryption. Specific PHI fields encrypted individually. Field-level approach protects data if other fields are compromised.
Production Target: Per-tenant encryption keys. Each law firm has its own unique encryption key. Key held in attorney-controlled KMS (Model C) or Signal Loom-managed HSM (Model B). No cross-tenant key sharing possible.
Algorithm: AES-256-GCM with random IV per encryption operation. Key derivation: HKDF with per-record salt. Key rotation: annual mandatory rotation with 90-day re-encryption window.
Current: TLS 1.3 enforced on all connections. Certificate pinning for mobile clients. HSTS (HTTP Strict Transport Security) with 1-year max-age.
Production Target: TLS 1.3 with certificate pinning on all clients. Certificate Transparency logs monitored. Post-quantum key exchange consideration for long-term secret protection.
Signal Loom Legal Pre-Flight does NOT store raw medical records. The system stores a structured digest — a summary of clinical facts extracted from the records.
Stored (digest only): Case type, jurisdiction, injury descriptions, provider names (not full addresses), treatment dates (not times), diagnoses (coded), deviation flags, attorney work product notes.
NOT stored: Full medical records, imaging files, audio files (transcribed and discarded), Social Security numbers, driver's license numbers.
De-identified analytics: Usage analytics are maintained separately from case data. Analytics contain no PHI. Used for product improvement only.
| Requirement | Current State | Production Target |
|---|---|---|
| Log scope | Per-action logging with user ID, timestamp, IP, action type, data accessed | Immutable append-only logs. No delete or modify operations permitted on log entries. |
| Log integrity | Logs stored in append-only database table | Cryptographic integrity hash per log entry (SHA-256). Tampering detectable via hash chain verification. |
| Retention | Duration not formally defined | 6-year minimum retention (HIPAA minimum). Logs retained in geographically separate storage with 30-day hot cache. |
| Access | Attorney-owned data: attorney has read access to their own case audit logs | Attorney-owned audit trail. Signal Loom staff access requires explicit written authorization from attorney. All access logged. |
| Alerting | Basic error logging for system health | Real-time alerting on anomalous access patterns (multiple failed auth, access outside business hours, bulk data export). |
Current: Attorney can export their case data in structured JSON format. Export requires active MFA session.
Production Target: One-click full case export including all Pre-Flight analysis output, flag history, and audit log entries. Format: portable JSON + PDF report bundle. Export is attorney-initiated, self-served, no Signal Loom staff involvement required.
When an attorney deletes their account or a specific case:
No soft delete recovery: After cryptographic erasure, there is no recovery path. This is intentional — it protects the attorney from both accidental and coerced data recovery.
SLA commitment: Signal Loom will notify affected attorneys within 24 hours of confirmed breach of unsecured PHI. Notification includes: nature of breach, types of PHI involved, steps taken to contain breach, remedial measures recommended.
Attorney's obligation: The attorney, as a business associate or covered entity depending on deployment model, has independent breach notification obligations to HHS and affected individuals. Signal Loom's 24-hour notification gives the attorney time to fulfill their regulatory obligations.
Incident response plan: A documented incident response plan is maintained and tested annually. Includes: breach confirmation criteria, containment procedures, forensics protocol, notification procedures, post-incident review.
| HIPAA Requirement | Implementation | Model A | Model B | Model C |
|---|---|---|---|---|
| §164.308(a)(1) Security Management Process | Risk analysis + risk management plan. Annual review. | ✓ | ✓ | ✓ |
| §164.308(a)(3) Workforce Security | Role assignment, access authorization, termination procedures. | ✓ | ✓ | ✓ |
| §164.308(a)(5) Security Awareness Training | Annual training required for all staff with PHI access. | ✓ | ✓ | ✓ |
| §164.312(a)(1) Access Control | Unique user IDs, automatic logoff, encryption/decryption. | ✓ | ✓ | ✓ |
| §164.312(b) Audit Controls | Hardware, software, procedural mechanisms to record access. | ✓ | ✓ | Limited |
| §164.312(c)(1) Integrity | Authenticate ePHI. Mechanism to authenticate data. | ✓ | ✓ | ✓ |
| §164.312(e)(1) Transmission Security | TLS 1.3. Encryption in transit. | ✓ | ✓ | ✓ |
| §164.400 HIPAA Breach Notification Rule | 24-hour notification SLA to downstream covered entities. | N/A (no PHI) | ✓ | N/A (no PHI) |