Section 16: Protected Health Information and De-identified Data

Section 16: Protected Health Information and De-identified Data

The following elements constitute PHI in any medium:  name, postal address, telephone numbers, fax numbers, Social Security number, medical record number, health plan beneficiary number, account number, certificate/license number, vehicle identifiers and serial number, including license plate number, device identifiers and serial number, Web Universal Resource Locators (“URLs”), Internet Protocol (“IP) address number, biometric identifiers, including finger and voice prints, full face photographic images and any comparable images.

De-identified Information shall not be subject to the protections and rights set forth in this Manual for PHI.

For all purposes, to constitute De-identified Information, PHI must be de-identified by removing all of the following information about the Individual and his or her family and household members:

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.

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; and

R. Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section; and

The Callier Center does not have actual knowledge that the information could be used alone or in combination with other information to identify an individual who is a subject of the information; or

HIPAA Regulatory Citations:  45 CFR § 164.514(a), § 164.502(d)

Effective:  09/01/2013
Revised:  05/19/2015
Reviewed: 10/21/2022, 03/24/2021, 08/13/2015

Heather Zimmerman, HIPAA Privacy Officer
UT Dallas Callier Center