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Limited Data Set

A limited data set is protected health information that excludes the following direct identifiers of the individual or of relatives, employers, or household members of the individual:

(i) Names;
(ii) Postal address information, other than town or city, State, and zip code;
(iii) Telephone numbers;
(iv) Fax numbers;
(v) Electronic mail addresses;
(vi) Social security numbers;
(vii) Medical record numbers;
(viii) Health plan beneficiary numbers;
(ix) Account numbers;
(x) Certificate/license numbers;
(xi) Vehicle identifiers and serial numbers, including license plate numbers;
(xii) Device identifiers and serial numbers;
(xiii) Web Universal Resource Locators (URLs);
(xiv) Internet Protocol (IP) address numbers;
(xv) Biometric identifiers, including finger and voice prints; and
(xvi) Full face photographic images and any comparable images.

In general, because of contractual requirements associated with a limited data set, you should seek to acquire PHI for research purposes with one of the other HIPAA PHI release mechanisms.  If these other mechanisms do not meet your needs, please contact the UB Director of HIPAA compliance (remove spaces hipaa-compliance @ buffalo.edu) to further examine this mechanism.

Important Note:  New York State Law sets additional requirements on the disclosure of certain types of information by health care workers, including but not limited to: Cancer Information, Communicable Diseases within New York City , HIV/AIDS, Tuberculosis, Sexual Abuse, Drug Abuse, Births and Deaths, Early Intervention Services, Genetic Information, Alcohol and Substance Abuse, and Mental Health.  In situations where research involves such information, State Law requirements, in addition to HIPAA requirements need to be considered.  A limited data set agreement does not remove the need to understand and comply with any additional requirements governing disclosures associated with these types of information.

This material is designed for internal University at Buffalo use only and is copyrighted.  Information and documents available on this site may be freely copied and used with appropriate attribution to the University at Buffalo.  None of the information on these pages should be construed as legal advice or expert opinion with respect to how any particular function or entity engages in work to come into compliance with HIPAA.
Last updated: July 28, 2009.  Privacy Policy
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