Who owns my dental office passwords and IT accounts?
On this page
- Key facts
- What counts as "my passwords"?
- Does it matter that my IT company created the accounts?
- What does HIPAA actually require?
- Who owns my domain name?
- How do I take inventory of what I own?
- Does owning my passwords mean I should manage IT myself?
- How FloorStack helps
- Free tools for this step
- Frequently asked questions
- Sources
Your practice does. Even when an IT company created the accounts, the logins belong to the business that pays for and depends on them (ITS). HIPAA also makes your practice responsible for keeping patient data available, and as of 2026 it requires an emergency access procedure for that data (45 CFR 164.312).
Key facts
| Item | What the rule or guidance says | Source |
|---|---|---|
| Who is responsible for data availability | The covered entity (your practice) is responsible for ensuring the availability of its own PHI | HHS OCR FAQ 2074 |
| Can a vendor holding your data block your access? | No; blocking a covered entity's access, for example over a payment dispute, is an impermissible use of PHI | HHS OCR FAQ 2074 |
| Unique user identification | Required implementation specification | 45 CFR 164.312(a)(2)(i) |
| Emergency access procedure | Required implementation specification | 45 CFR 164.312(a)(2)(ii) |
| Data backup and disaster recovery plans | Required | 45 CFR 164.308(a)(7) |
| Security documentation retention | 6 years from creation or last effective date | HHS Security Rule summary |
What counts as "my passwords"?
More than most owners think. In a typical dental office, the keys to the practice include:
- Domain name and DNS (registrar account), which controls your website and email delivery.
- Email and productivity admin (Microsoft 365 or Google Workspace global administrator).
- Practice-management and imaging software administrator accounts and database credentials.
- Firewall, router, switches and Wi-Fi admin logins, plus the Wi-Fi passphrases.
- Server and workstation local administrator accounts.
- Backup consoles and any cloud backup encryption keys.
- Internet, phone and fax carrier accounts.
- Security cameras (the recorder or cloud portal) and door-access systems.
- Website hosting, clearinghouse, e-prescribing and insurance portals.
If you cannot name who holds the top-level login for each of these, you do not fully control your practice. Put simply: your practice shouldn't be held hostage by whoever installed it.
Does it matter that my IT company created the accounts?
Not to ownership. An IT firm writing on this exact question puts it plainly: "you and you alone have full ownership over your credentials. Even if your IT provider creates the accounts you use, the rights over them still fall under your umbrella" (ITS). You granted your provider access so it could manage your systems; it did not acquire your systems.
Your contract still matters, because it governs how and when handover happens. U.S. and allied cybersecurity agencies tell managed-service customers to make sure contracts "transparently identify ownership of ICT security roles and responsibilities" (CISA advisory AA22-131A). See what your IT contract should say about passwords and data.
To list every account the practice should own, the free credential ownership checklist (coming soon) will include a "password hostage" letter template you can adapt.
What does HIPAA actually require?
HIPAA does not use the phrase "password ownership," but several Security Rule requirements only work if your practice can reach its own systems:
- Availability. Covered entities must ensure the confidentiality, integrity and availability of the ePHI they hold (HHS). HHS has said a covered entity that signs contract terms preventing it from ensuring the availability of its own PHI is itself out of compliance (HHS OCR FAQ 2074).
- Emergency access. You must establish procedures for obtaining necessary ePHI during an emergency (45 CFR 164.312(a)(2)(ii)). A procedure that depends on one outside technician answering the phone is fragile.
- Unique user IDs. Each user needs a unique name or number for identifying and tracking activity (45 CFR 164.312(a)(2)(i)). Shared "admin/admin" logins undermine this.
- Ending access. Procedures for terminating access when an employment or "other arrangement" ends are an addressable specification (45 CFR 164.308(a)(3)(ii)(C)). You cannot revoke what you cannot see.
- Business associate agreements. Any vendor that creates, receives, maintains or transmits ePHI for you needs a BAA (HHS).
For the full checklist, see what the HIPAA Security Rule requires for dental IT. This is general information, not legal advice.
Who owns my domain name?
Whoever is listed as the registrant. If a web designer or IT company registered your domain under its own name, changing that requires going through the registrar where it is registered; ICANN directs registrants to contact that registrar and to look up the registrar through a WHOIS search (ICANN). ICANN also notes registrars must apply a 60-day transfer lock after a change of registrant unless the registrant opts out where offered (ICANN). Fix this while relationships are good, not during a dispute.
How do I take inventory of what I own?
Do this once, then keep it current.
- List every system from the section above. Note the vendor, the account URL and who holds the top-level login.
- Create a practice-owned admin account on each system where the vendor allows it, in the practice's name, with multi-factor authentication tied to a practice-controlled phone or key.
- Store credentials in a practice-controlled vault, not a technician's notebook or personal password manager.
- Confirm the domain registrant and the email global admin are the practice.
- Get the network documentation: firewall config backup, switch port map, IP plan and Wi-Fi settings. See how a dental office network should be designed.
- Verify backups are restorable by you, including where encryption keys live. See how to back up patient data.
- Review quarterly and after any staff or vendor change. CISA's first tactical recommendation is to identify and disable accounts no longer in use (CISA).
To see this on your own floor plan, FloorStack Studio (live, free plan) builds a 3D IT plan of your office with every device placed.
Does owning my passwords mean I should manage IT myself?
No. Owning the keys and doing the work are different jobs. A good IT provider should have its own named accounts, logged and revocable, while your practice holds the master access. That arrangement protects both sides: the provider can prove what it did, and you can change providers without a crisis. If you are already mid-dispute, read Can my IT company refuse to give me my passwords? and how to switch IT providers without losing access.
How FloorStack helps
FloorStack is a dental build-out platform that also documents what gets built. Our free IT Credential Ownership Checklist (coming soon at /tools/credential-ownership-checklist) will walk you through every system above and flag gaps. As described on the FloorStack homepage, FloorStack keeps each login with its device in a BAA-backed vault and lets you grant or revoke access for your MSP, staff or vendors at any time. Start at the Own Your Dental Passwords hub.
Free tools on the FloorStack dental build-out platform for this step: FloorStack Studio (live, free plan).
Free tools for this step
- FloorStack Studio (live, free plan): a 3D IT plan of your office with every device placed.
- Credential ownership checklist (free tool, coming soon): list every admin account the practice should own, with a "password hostage" letter template.
Frequently asked questions
Does my IT company own the passwords it created?
No. The accounts exist to run your practice, so the credentials belong to the practice, even when a provider created them. Your contract should spell out handover terms.
Does HIPAA require me to have my own admin passwords?
HIPAA does not use that wording. It does require an emergency access procedure, unique user IDs and contingency plans, and HHS says covered entities are responsible for the availability of their own PHI. Holding master access is the practical way to meet those duties.
Can a software vendor lock me out over an unpaid bill?
HHS says a business associate that blocks a covered entity's access to PHI it maintains, for example to resolve a payment dispute, has made an impermissible use of PHI and is violating the Security Rule.
Who owns my practice website domain?
The registrant listed with the registrar. If that is your IT company or web designer, ask them to change the registrant to your practice and contact the registrar if they will not.
What should be in my credential inventory?
Domain and DNS, email admin, practice-management and imaging admin, firewall and Wi-Fi, server and local admin, backups and keys, carriers, cameras, door access and web hosting.
How often should I review who has access?
At least quarterly and every time an employee, contractor or vendor leaves. Disable accounts no longer in use.
Sources
- FloorStack homepage
- HHS OCR FAQ 2074: May a business associate block or terminate a covered entity's access to PHI?
- HHS: Summary of the HIPAA Security Rule
- 45 CFR 164.312, Technical safeguards (LII)
- 45 CFR 164.308, Administrative safeguards (LII)
- CISA et al., Advisory AA22-131A: Protecting Against Cyber Threats to MSPs and their Customers
- ITS: Can an IT Company Withhold Your Login Credentials? (2023)
- ICANN: About Change of Registrant
More in Own Your Dental Passwords
- Can Your IT Company Refuse to Give You Your Passwords?An IT company holding your patient data can't lock you out over a billing dispute, HHS says. What to do in 2026 if your dental IT provider withholds access.6 min read
- How to Switch Dental IT Providers Without Losing Access (2026)A 2026 step-by-step plan for switching dental IT providers: inventory, owner admin accounts first, credential handover, BAA data return, and a 30-day checklist.6 min read
- Is Your Dental Equipment Registered to You? How to Check and Fix ItCheck who your dental equipment is registered to in 2026: x-ray state registration, warranty invoices, software licenses and vendor portals, and how to fix it.5 min read
- How to Document a Dental Client's Network and DevicesA 2026 MSP guide to documenting a dental client's network: asset inventory fields, network map, credentials, vendor access and a handover-ready format.6 min read
- Sharing Credentials With Dental Clients: Owner-Controlled AccessHow an MSP should share credentials with a dental client in 2026: practice-owned vault, named accounts, MFA, emergency admin access and logged handoffs.5 min read
- Taking Over a Dental Client From Another MSP: Credential Handoff PlanA 2026 credential handoff plan for MSPs taking over a dental client: owner-led requests, domain, Microsoft 365, firewall, backups, BAAs and old-MSP offboarding.5 min read