Who holds what
Listen's maker never creates, receives, maintains, or
transmits PHI on your behalf: there is no server, no account, and no
support channel that touches your library. HIPAA's obligations therefore
sit where your data sits, with you, and the software's job is to be
deployable in a compliant configuration. This page is that
configuration.
There is no such thing as a HIPAA certification, for Listen or for
anything else; HHS recognises no certifying body. What a diligent buyer can
ask for is exactly what this page and the
security page provide: the controls, their
locations in the code, and the way to verify them.
The three rules that matter most
- Keep iCloud sync off for PHI libraries. Apple does
not sign Business Associate Agreements for iCloud, and HHS treats even a
no-view host of ciphertext as a business associate. Sync is off by
default; a device profile can force it off so nobody can turn it on. The
end-to-end sealing is real, but the BAA question is about paperwork
Apple does not offer, so the guide's answer is: not for PHI.
- Keep AI on the machine, or under your own BAA. The
Chat feature sends the meetings you ask about to whatever endpoint you
configure. Loopback endpoints (Ollama, LM Studio) send nothing anywhere
and are always fine. A hosted provider is fine only under a BAA you hold
with that provider (Microsoft Azure OpenAI, Anthropic, and OpenAI all
offer them). The Claude and Codex desktop harnesses send transcripts to
their vendors, so treat them the same way. A profile can force
Chat to loopback only.
- Leave promises off for PHI. The Promises page is read
by TypeSafe’s hosted decision model with a key you enter, and it is
sent the transcript lines of one conversation at a time. There is no BAA
with TypeSafe, so do not enter a TypeSafe key on a Mac that records
PHI.
The Mac checklist
- FileVault on. The library is plain files under the
user's account; whole-disk encryption is the at-rest control.
- One macOS account per person, with a login password
and automatic screen lock. That is HIPAA's unique-user-identification and
automatic-logoff, provided by the OS.
- Install the device profile.
listen-managed.mobileconfig
forces sync off, Chat to loopback only, the dictation history off, and
anonymous usage statistics off. Telemetry is on by default elsewhere, so
this is the key that matters here: it disables the Settings, Privacy
toggle rather than merely pre-declining it.
MANAGED.md
documents every key and how to verify it took.
- Backups on encrypted storage. Listen's daily copies
under
~/Backups/Listen are owner-only and covered by
FileVault; Time Machine targets should be encrypted volumes. Deleted
recordings persist in backups for up to 7 days (clones) and 30 days
(sidecar archives); that retention schedule is part of your risk
analysis.
- Know your audit trail.
listen activity
shows every tool call, agent run, export, deletion and backup, with
recording ids and no content.
- Be deliberate about MCP. Any agent you connect can
read the whole library through the stdio server. Connect only tools your
policies cover, and remember the activity log records their calls.
The iPhone checklist
- Device passcode (Face ID counts). The library sits
under iOS Data Protection keyed off it.
- Storage, Include in iPhone backups: off, unless the
user runs Apple's Advanced Data Protection. A device backup is a copy in
a cloud whose keys Apple holds by default, which is rule one again in
different clothes.
- Sync off, as on the Mac, and for the same reason.
Without it the phone app is an entirely local recorder.
People's biometrics and consent
- Voiceprints are deletable, everywhere. "Forget this
person" (in the People pane, or
listen forget) strips their
voice embeddings from every recording and propagates the forget across
devices and iCloud. Use it when a patient or colleague asks to be
removed.
- Consent to record is your obligation. Two-party
consent states, national recording laws, and your own consent workflows
sit outside any software. Nothing in Listen makes an unlawful recording
lawful.
What a security questionnaire will ask
Where is PHI stored? On the covered entity's own devices only.
Who can access it? The OS account that owns the library.
Is it encrypted at rest? FileVault (required) / iOS Data Protection.
Is it encrypted in transit? Nothing transits by default. Optional sync is
end-to-end ChaCha20-Poly1305; hosted AI requires
https and the customer's own BAA.
Vendor access to PHI? None. No server, no account, no remote support.
Audit logging? activity.jsonl, ids only, listen activity to read.
Subprocessors? None for product data. PostHog (EU) receives
anonymous usage counts, on by default, that can
never contain PHI; the managed profile forces
it off entirely.
The caveat that belongs on every page like this
This is engineering documentation written by the people who built the
software, not legal advice. Have your privacy officer or counsel review
your deployment against your own risk analysis. The architecture was
built to make that review short.