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Identifiers
This page lists the identifiers specifically appearing in the HIPAA privacy
regulations. The presence of any one of these identifiers renders
health information individually identifiable.
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'. Note that tissue samples
themselves are not considered identifiers (unless labeled in some manner with
one of the identifiers below).
The following identifiers of the individual or of relatives, employers, or household members of the
individual (* Indicates permitted in a limited dataset §164.514(e)(2)):
| (A) |
Names |
| (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 |
| (R)* |
Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section; [creation of a unique code not disclosed to the investigator or investigator creation of such a code with a BA in place]
NB: 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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