Data De-identification Checklist

Confirm the following 18 identifiers have been removed from the dataset. This requirement includes data elements related to the individual or relatives, employers, or household members of the individual.

  1. Names
  2. Subdivisions smaller than a state, including:
    • Street Addresses
    • City
    • County
    • Precinct
    • Zip Code
  3. All elements of dates (except year) or 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 (except year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older.
  4. Telephone numbers
  5. Fax numbers
  6. Electronic mail addresses
  7. Social Security numbers
  8. Medical Record numbers
  9. Health plan beneficiary numbers
  10. Account numbers
  11. Certificate/license numbers
  12. Vehicle identifiers and serial numbers, including license plate numbers
  13. Device identifiers and serial numbers
  14. Web universal resource locators (URLs)
  15. Internet Protocol (IP) address numbers
  16. Biometric identifiers, including finger and voice prints
  17. Full-face photographic images and any comparable images
  18. Any other unique identifying number, characteristic, or code, except as permitted by the re-identification rules, below.


A researcher authorized to view the PHI may assign a code or other means of record identification to allow de-identified information to be re-identified, provided that:

  1. Derivation: The code or other means of record identification is not derived from or related to information about the individual and is not otherwise capable of being translated so as to identify the individual; and
  2. Security: The authorized researcher does not use or disclose the code or other means of record identification for any other purpose, and does not disclose the mechanism for re-identification.

See Also / Return To:
Topic revision: r3 - 18 Oct 2006, RobertGreevy

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