With Microsoft officially ending support for Windows 10 in October 2025, healthcare organizations now face a critical technology decision: migrate to Windows 11 or risk operating on unsupported infrastructure. For an industry already under immense pressure, this might feel like just another admin task, but it’s one that has significant implications for security, compliance, and patient trust.
The Risk of Waiting
As the end-of-support date approaches, fewer applications and tools will remain fully compatible with Windows 10. That can lead to degraded performance, reduced capabilities, and growing frustration for clinical and administrative teams. But more critically, starting October 14, Microsoft will stop releasing security updates, bug fixes, and technical support for Windows 10.
While your systems won’t stop working overnight, they’ll become increasingly vulnerable to cyberattacks and software failures. Unsupported software is a known entry point for attackers, and in healthcare, that risk translates to potential data breaches, operational disruptions, and regulatory violations.
A Compliance Deadline, Not Just a Tech Deadline
For organizations handling electronic protected health information (ePHI), this migration isn’t optional — it’s a compliance necessity. Under HIPAA’s Security Rule, covered entities must implement risk management strategies that include maintaining up-to-date systems and applying security patches to protect sensitive information. Once Windows 10 support ends, continuing to use it may constitute a HIPAA violation.
The Department of Health and Human Services (HHS) has addressed this directly in its official guidance: operating outdated or unsupported systems can result in non-compliance. If your organization is audited, using an unsupported OS will be difficult to justify, especially given the well-publicized nature of this transition.
Windows 11: Privacy by Design, Not Just a New Interface
Upgrading to Windows 11 isn’t just about checking a compliance box; it also brings meaningful security and privacy enhancements. One of the most significant is the requirement for TPM 2.0 (Trusted Platform Module), a hardware-based security layer that enables secure boot, encrypted credentials, and tamper protection from the moment the system powers on.
Together with features like virtualization-based security, cryptographic attestation, and improved default settings, Windows 11 helps reduce human error and enforce better protection of sensitive data without requiring constant manual oversight.
It also addresses one of the healthcare industry’s perennial challenges: transparency. Windows 11 introduces new telemetry controls and an updated privacy dashboard, including a Diagnostic Data Viewer that provides real-time insights into what data is being collected, how it’s used, and why. This level of visibility supports Privacy Impact Assessments (PIAs), internal audits, and regulatory reporting — making it easier to demonstrate accountability to patients and auditors alike.
Revisiting DPIAs and Consent Management
These architectural changes necessitate a review of your Data Protection Impact Assessments (DPIAs). Many risks identified under Windows 10, such as weak encryption or extensive telemetry, may be reduced or eliminated under Windows 11. This creates an opportunity to reclassify data risks, streamline mitigation strategies, and reduce unnecessary processing.
Organizations should also take this opportunity to rethink their approach to consent management. While Microsoft now offers more precise controls for telemetry and diagnostics, implementation remains the responsibility of the healthcare provider. Tools like Microsoft Endpoint Manager and enhanced Group Policy settings enable IT teams to centrally manage consent preferences, document changes, and maintain audit trails, making it easier to meet both HIPAA and GDPR obligations.
Most importantly, these improvements can elevate the user experience. When patients and staff understand what data is collected and why it is collected, they can feel confident that their preferences are being respected, privacy risks decrease, and trust increases.
Planning for a Smooth Transition
For organizations already running Windows 10 on supported hardware, the upgrade to Windows 11 should be relatively seamless. Most applications, settings, and system configurations can be migrated without disruption. If you’re already subscribed to a HIPAA-compliant Microsoft 365 plan, the process is even more straightforward.
That said, any firm relying on legacy 32-bit applications, unsupported devices, or outdated security controls may need to take additional steps. In some cases, a clean install or hardware upgrade may be required to meet Windows 11’s security standards. And regardless of your system’s current state, it’s wise to treat this transition as more than just an IT project; it’s a strategic inflection point.
Use the Migration to Build Long-Term Trust
A HIPAA health check in the context of a Windows 11 migration can help identify compliance gaps, shore up your security posture, and lay the foundation for more secure digital operations moving forward. However, beyond the technical benefits, this also presents an opportunity to reinforce your organization’s commitment to transparency, trust, and patient privacy.
Incorporating privacy-by-design principles into your migration strategy by limiting unnecessary data collection, strengthening telemetry controls, and maintaining clear documentation not only reduces risk but also positions your organization for success in a healthcare landscape where trust is a key differentiator.
Migrating to Windows 11 shouldn’t just be about ticking a compliance box. Done right, it can become a visible, strategic move that reassures patients, empowers staff, and positions your organization for secure growth in the years ahead.
About Sam Peters
Sam Peters has a diverse work experience starting from 2003 to present. They are currently serving as the Chief Product Officer at ISMS.online since May 2021. Previously, they worked at Alliantist for 8 years, from January 2013 to May 2021, in the role of Head of Products and Services. Before that, they held the position of Product and Support Manager at WPM Education from June 2011 to January 2013. Prior to that, they worked at East Sussex County Council as a Schools ICT Applications Manager from September 2009 to June 2011. They also worked as a General Manager at DB Education Services from April 2008 to September 2009. Their earliest professional experience was at Digitalbrain PLC, where they served as a Service Delivery Manager from November 2003 to April 2008.
