General Discussion
In reply to the discussion: Let me tell you about a little girl my wife is treating. [View all]The Velveteen Ocelot
(116,499 posts)Identifiers
This lists the identifiers specifically appearing in the HIPAA privacy regulations. The presence of any one of these identifiers renders health information individually identifiable. If none of these is a part of the information, it is not possible to identify the individual and no HIPAA violation occurs if the information is used.
HIPAA De-identification requires removal of all such identifiers as specifically defined in the regulations. It is not equivalent to the more general concept associated with the term 'anonymous.' (my emphasis)
The following identifiers of the individual or of relatives, employers, or household members of the individual the asterisk * indicates permitted in a limited data set §164.514(e)(2)):
(A) Names (unless specifically released by written permission)
(B)* All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:
(1) The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
(2) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
[Limited dataset must exclude postal address information other than town or city, state and zip code]
(C)* All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;
(D) Telephone numbers
(E) Fax numbers
(F) Electronic mail addresses
(G) Social security numbers
(H) Medical record numbers
(I) Health plan beneficiary numbers
(J) Account numbers
(K) Certificate/license numbers
(L) Vehicle identifiers and serial numbers, including license plate numbers
(M) Device identifiers and serial numbers
(N) Web Universal Resource Locators (URLs)
(O) Internet Protocol (IP) address numbers
(P) Biometric identifiers, including finger and voice prints
(Q) Full face photographic images and any comparable images (unless written permission obtained)
(R)* Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section; If the algorithm for creating a "code" is disclosed to the recipient of the information, then the code is considered a unique identifier. The code is also considered a unique identifier if it is generated from any of the identifiers, or pieces of the identifiers, listed above.
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