Deidentified Data

Health information that does not include individual identifiable data elements and cannot be combined with a code or other information to re-identify an individual is considered de-identified information and not subject to the same protections as individually identifiable health information. If a code or other information to re-identify data is disclosed, the information is no longer considered de-identified and Privacy Rule requirements (such as authorization and minimum necessary) for use and disclosure apply.

Certain departments may be able to utilize de-identified information when performing certain business related activities. For example, departments may be able to use de-identified information for data aggregation purposes. For non-research activities, the Information Services (HS) department will create de-identified information for you to ensure that information has been properly de-identified and that there is minimal potential for re-identification through means of a code or other information. To request that information be de-identified, complete an IS Service Request form.

For research activities, you must receive approval from the Institutional Review Board (IRB) Administrator in the Office of Sponsored Research prior to the creation and utilization of de-identified information.

Data fields that identify a patient are:

• Names
• Address (all geographic subdivisions smaller than a state).
• Zip Codes*
• Dates (except year) for:
• Birth dates
• Admission dates
• Discharge date
• Date of death
• Dates (including year) for:All ages over 89**
• Telephone numbers
• Fax numbers
• Electronic mail addresses
• Social security numbers
• Medical record numbers
• Health plan beneficiary numbers
• Account numbers
• Certificate/license numbers
• Vehicle identifiers and serial numbers, including license plate numbers
• Device identifiers and serial numbers
• Web Universal Resource Locators (URLs)
• Internet Protocol (IP) address numbers
• Biometric identifiers, including finger and voice prints
• Full face photographic images and any comparable images
• Any other unique identifying number, characteristic, or code***

* The initial three digits of a zip code can be used if, according to the Bureau of the Census, the geographic unit formed by combining all zip codes contains more than 20,000 people and, for the other geographic units that are fewer than 20,000, the initial 3 digits are changed to 000.

** except that such ages and elements be aggregated into a single category of age 90 & older

*** except for re-identification codes that follow appropriate rules

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