The De-identification of Personally Identifiable Information

Size: px
Start display at page:

Download "The De-identification of Personally Identifiable Information"

Transcription

1 The De-identification of Personally Identifiable Information Khaled El Emam (PhD) Laurier Avenue W, Suite 200 Ottawa, ON Canada K1P 5J6

2 De-identification Works

3 Anonymization = Risk Management

4 Direct & Quasi-identifiers Examples of direct identifiers: Name, address, telephone number, fax number, MRN, health card number, health plan beneficiary number, VID, license plate number, address, photograph, biometrics, SSN, SIN, device number, clinical trial record number Examples of quasi-identifiers: sex, date of birth or age, geographic locations (such as postal codes, census geography, information about proximity to known or unique landmarks), language spoken at home, ethnic origin, total years of schooling, marital status, criminal history, total income, visible minority status, profession, event dates, number of children, high level diagnoses and procedures

5 2 Anonymization Landscape

6 HIPAA Safe Harbor Method Safe Harbor Direct Identifiers and Quasi-identifiers 1. Names 2. ZIP Codes (except first three) 3. All elements of dates (except year) 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

7 Expert Determination (Statistical) Method A person with appropriate knowledge of and experience with generally accepted statistical and scientific principles and methods for rendering information not individually identifiable: I. Applying such principles and methods; determines that the risk is very small that the information could be used, alone or in combination with other reasonably available information by an anticipated recipient to identify an individual who is a subject of the information; and II. Documents the methods and results of the analysis that justify such determination

8 Spectrum of Identifiability 1 Cell Size 3 Two matching indirect identifiers in three cells within a dataset

9 Spectrum of Identifiability There are a range of operational precedents, based on situational context and mitigating controls Little De-identification Significant De-identification

10 Managing Re-identification Risk

11 De-identification Process Set Risk Threshold Based on the characteristics of the data recipient, the data, and precedents and quantitative threshold is set. This is an iterative process. The mitigating controls in place can be strengthened to get a more forgiving threshold. De-identification Process Measure Risk Based on plausible attacks, appropriate metrics are selected and used to measure actual reidentification risk from the data. Apply Transformations If the measured risk does not meet the threshold, specific transformations (such as generalization and suppression) are applied to reduce the risk.

12 Automation

13 Enabling Post-marketing and Public Health Surveillance Large EMR Vendor Challenge Wants to anonymize data on 535,595 patients from general practices Longitudinal data needs to be used for on-going and on-demand analytics Solution PARAT CORE PARAT integrated in ETL pipeline Why Privacy Analytics De-identified data would allow: 1. Post-marketing surveillance of adverse events 2. Public health surveillance 3. Prescription pattern analysis 4. Health services analysis Customer Profile EMR vendor with more than 2664 clinics and 5850 physicians using the system in family clinics and walk-in clinics. The data set spans more than five years of all clinical, prescription, laboratory, scheduling and billing data.

14 GI Protocol Two arm protocol; GI events after taking NSAIDs with and without a PPI

15 Chlamidya Protocol Females years old inclusive tested and tested positive for Chlamydia in the previous 12 months

16

ENSURING ANONYMITY WHEN SHARING DATA. Dr. Khaled El Emam Electronic Health Information Laboratory & uottawa

ENSURING ANONYMITY WHEN SHARING DATA. Dr. Khaled El Emam Electronic Health Information Laboratory & uottawa ENSURING ANONYMITY WHEN SHARING DATA Dr. Khaled El Emam Electronic Health Information Laboratory & uottawa ANONYMIZATION Motivations for Anonymization Obtaining patient consent/authorization not practical

More information

Protecting Patient Privacy. Khaled El Emam, CHEO RI & uottawa

Protecting Patient Privacy. Khaled El Emam, CHEO RI & uottawa Protecting Patient Privacy Khaled El Emam, CHEO RI & uottawa Context In Ontario data custodians are permitted to disclose PHI without consent for public health purposes What is the problem then? This disclosure

More information

De-Identification of Health Data under HIPAA: Regulations and Recent Guidance" " "

De-Identification of Health Data under HIPAA: Regulations and Recent Guidance  De-Identification of Health Data under HIPAA: Regulations and Recent Guidance" " " D even McGraw " Director, Health Privacy Project January 15, 201311 HIPAA Scope Does not cover all health data Applies

More information

How to De-identify Data. Xulei Shirley Liu Department of Biostatistics Vanderbilt University 03/07/2008

How to De-identify Data. Xulei Shirley Liu Department of Biostatistics Vanderbilt University 03/07/2008 How to De-identify Data Xulei Shirley Liu Department of Biostatistics Vanderbilt University 03/07/2008 1 Outline The problem Brief history The solutions Examples with SAS and R code 2 Background The adoption

More information

Administrative Services

Administrative Services Policy Title: Administrative Services De-identification of Client Information and Use of Limited Data Sets Policy Number: DHS-100-007 Version: 2.0 Effective Date: Upon Approval Signature on File in the

More information

What is Covered by HIPAA at VCU?

What is Covered by HIPAA at VCU? What is Covered by HIPAA at VCU? The Privacy Rule was designed to protect private health information from incidental disclosures. The regulations specifically apply to health care providers, health plans,

More information

HIPAA POLICY REGARDING DE-IDENTIFICATION OF PROTECTED HEALTH INFORMATION AND USE OF LIMITED DATA SETS

HIPAA POLICY REGARDING DE-IDENTIFICATION OF PROTECTED HEALTH INFORMATION AND USE OF LIMITED DATA SETS HIPAA POLICY REGARDING DE-IDENTIFICATION OF PROTECTED HEALTH INFORMATION AND USE OF LIMITED DATA SETS SCOPE OF POLICY: What Units Are Covered by this Policy?: This policy applies to the following units

More information

SCHOOL OF PUBLIC HEALTH. HIPAA Privacy Training

SCHOOL OF PUBLIC HEALTH. HIPAA Privacy Training SCHOOL OF PUBLIC HEALTH HIPAA Privacy Training Public Health and HIPAA This presentation will address the HIPAA Privacy regulations as they effect the activities of the School of Public Health. It is imperative

More information

HIPAA-Compliant Research Access to PHI

HIPAA-Compliant Research Access to PHI HIPAA-Compliant Research Access to PHI HIPAA permits the access, disclosure and use of PHI from a HIPAA Covered Entity s or HIPAA Covered Unit s treatment, payment or health care operations records for

More information

UPMC POLICY AND PROCEDURE MANUAL

UPMC POLICY AND PROCEDURE MANUAL UPMC POLICY AND PROCEDURE MANUAL POLICY: INDEX TITLE: HS-EC1807 Ethics & Compliance SUBJECT: Honest Broker Certification Process Related to the De-identification of Health Information for Research and

More information

De-Identification 101

De-Identification 101 De-Identification 101 We live in a world today where our personal information is continuously being captured in a multitude of electronic databases. Details about our health, financial status and buying

More information

Extracting value from HIPAA Data James Yaple Jackson-Hannah LLC

Extracting value from HIPAA Data James Yaple Jackson-Hannah LLC Extracting value from HIPAA Data James Yaple Jackson-Hannah LLC Session Objectives Examine the value of realistic information in research and software testing Explore the challenges of de-identifying health

More information

IDAHO STATE UNIVERSITY POLICIES AND PROCEDURES (ISUPP) HIPAA Privacy - De-identification of PHI 10030

IDAHO STATE UNIVERSITY POLICIES AND PROCEDURES (ISUPP) HIPAA Privacy - De-identification of PHI 10030 IDAHO STATE UNIVERSITY POLICIES AND PROCEDURES (ISUPP) HIPAA Privacy - De-identification of PHI 10030 POLICY INFORMATION Major Functional Area (MFA): MFA X - Office of General Counsel & Compliance Policy

More information

Legal Insight. Big Data Analytics Under HIPAA. Kevin Coy and Neil W. Hoffman, Ph.D. Applicability of HIPAA

Legal Insight. Big Data Analytics Under HIPAA. Kevin Coy and Neil W. Hoffman, Ph.D. Applicability of HIPAA Big Data Analytics Under HIPAA Kevin Coy and Neil W. Hoffman, Ph.D. Privacy laws and regulations such as the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule can have a significant

More information

De-Identification of Clinical Data

De-Identification of Clinical Data De-Identification of Clinical Data Sepideh Khosravifar, CISSP Info Security Analyst IV TEPR Conference 2008 Ft. Lauderdale, Florida May 17-21, 2008 1 1 Slide 1 cmw1 Craig M. Winter, 4/25/2008 Background

More information

De-Identification of Clinical Data

De-Identification of Clinical Data De-Identification of Clinical Data Sepideh Khosravifar, CISSP Info Security Analyst IV Tyrone Grandison, PhD Manager, Privacy Research, IBM TEPR Conference 2008 Ft. Lauderdale, Florida May 17-21, 2008

More information

The De-identification Maturity Model Authors: Khaled El Emam, PhD Waël Hassan, PhD

The De-identification Maturity Model Authors: Khaled El Emam, PhD Waël Hassan, PhD A PRIVACY ANALYTICS WHITEPAPER The De-identification Maturity Model Authors: Khaled El Emam, PhD Waël Hassan, PhD De-identification Maturity Assessment Privacy Analytics has developed the De-identification

More information

HIPAA-P06 Use and Disclosure of De-identified Data and Limited Data Sets

HIPAA-P06 Use and Disclosure of De-identified Data and Limited Data Sets HIPAA-P06 Use and Disclosure of De-identified Data and Limited Data Sets FULL POLICY CONTENTS Scope Policy Statement Reason for Policy Definitions ADDITIONAL DETAILS Web Address Forms Related Information

More information

De-Identification Framework

De-Identification Framework A Consistent, Managed Methodology for the De-Identification of Personal Data and the Sharing of Compliance and Risk Information March 205 Contents Preface...3 Introduction...4 Defining Categories of Health

More information

HIPAA COMPLIANCE. What is HIPAA?

HIPAA COMPLIANCE. What is HIPAA? HIPAA COMPLIANCE What is HIPAA? The Health Insurance Portability and Accountability Act (HIPAA) also known as the Privacy Rule specifies the conditions under which protected health information may be used

More information

IRB Application for Medical Records Review Request

IRB Application for Medical Records Review Request Office of Regulatory Research Compliance Institutional Review Board FORM B1 : Medial Records Review Application FORM B1 IRB Application for Medical Records Review Request Principal Investigator: Email:

More information

Winthrop-University Hospital

Winthrop-University Hospital Winthrop-University Hospital Use of Patient Information in the Conduct of Research Activities In accordance with 45 CFR 164.512(i), 164.512(a-c) and in connection with the implementation of the HIPAA Compliance

More information

De-identification, defined and explained. Dan Stocker, MBA, MS, QSA Professional Services, Coalfire

De-identification, defined and explained. Dan Stocker, MBA, MS, QSA Professional Services, Coalfire De-identification, defined and explained Dan Stocker, MBA, MS, QSA Professional Services, Coalfire Introduction This perspective paper helps organizations understand why de-identification of protected

More information

De-identification Koans. ICTR Data Managers Darren Lacey January 15, 2013

De-identification Koans. ICTR Data Managers Darren Lacey January 15, 2013 De-identification Koans ICTR Data Managers Darren Lacey January 15, 2013 Disclaimer There are several efforts addressing this issue in whole or part Over the next year or so, I believe that the conversation

More information

4. No accounting of disclosures is required with respect to disclosures of PHI within a Limited Data Set.

4. No accounting of disclosures is required with respect to disclosures of PHI within a Limited Data Set. IDAHO STATE UNIVERSITY POLICIES AND PROCEDURES (ISUPP) HIPAA Privacy - Limited Data Sets and Data Use Agreements 10200 POLICY INFORMATION Major Functional Area (MFA): MFA X - Office of General Counsel

More information

HIPAA AND MEDICAID COMPLIANCE POLICIES AND PROCEDURES

HIPAA AND MEDICAID COMPLIANCE POLICIES AND PROCEDURES SALISH BHO HIPAA AND MEDICAID COMPLIANCE POLICIES AND PROCEDURES Policy Name: HIPAA BREACH NOTIFICATION REQUIREMENTS Policy Number: 5.16 Reference: 45 CFR Parts 164 Effective Date: 03/2016 Revision Date(s):

More information

HIPAA Medical Billing Requirements For Research

HIPAA Medical Billing Requirements For Research The Health Insurance Portability and Accountability Act (HIPAA) Excerpted from the UTC IRB Policy June 2008 Table of Contents PART V: The Health Insurance Portability and Accountability Act (HIPAA)...

More information

A Q&A with the Commissioner: Big Data and Privacy Health Research: Big Data, Health Research Yes! Personal Data No!

A Q&A with the Commissioner: Big Data and Privacy Health Research: Big Data, Health Research Yes! Personal Data No! A Q&A with the Commissioner: Big Data and Privacy Health Research: Big Data, Health Research Yes! Personal Data No! Ann Cavoukian, Ph.D. Information and Privacy Commissioner Ontario, Canada THE AGE OF

More information

A De-identification Strategy Used for Sharing One Data Provider s Oncology Trials Data through the Project Data Sphere Repository

A De-identification Strategy Used for Sharing One Data Provider s Oncology Trials Data through the Project Data Sphere Repository A De-identification Strategy Used for Sharing One Data Provider s Oncology Trials Data through the Project Data Sphere Repository Prepared by: Bradley Malin, Ph.D. 2525 West End Avenue, Suite 1030 Nashville,

More information

HIPAA COMPLIANCE INFORMATION. HIPAA Policy

HIPAA COMPLIANCE INFORMATION. HIPAA Policy HIPAA COMPLIANCE INFORMATION HIPAA Policy Use of Protected Health Information for Research Policy University of North Texas Health Science Center at Fort Worth Applicability: All University of North Texas

More information

What is Covered under the Privacy Rule? Protected Health Information (PHI)

What is Covered under the Privacy Rule? Protected Health Information (PHI) HIPAA & RESEARCH What is Covered under the Privacy Rule? Protected Health Information (PHI) Health information + Identifier = PHI Transmitted or maintained in any form (paper, electronic, forms, web-based,

More information

LA BioMed Secure Email

LA BioMed Secure Email INFORMATION SYSTEMS LA BioMed Secure Email Los Angeles Biomedical Research Institute at Harbor-UCLA 1124 W Carson St Bldg E2.5 Phone 310.222.1212 Table of Contents Intended Audience... 1 Purpose... 1 When

More information

Limited Data Set Background Information

Limited Data Set Background Information Limited Data Set Background Information 1. A limited data set is protected health information that excludes certain identifiers but permits the use and disclosure of more identifiers than in a de-identified

More information

Data Driven Approaches to Prescription Medication Outcomes Analysis Using EMR

Data Driven Approaches to Prescription Medication Outcomes Analysis Using EMR Data Driven Approaches to Prescription Medication Outcomes Analysis Using EMR Nathan Manwaring University of Utah Masters Project Presentation April 2012 Equation Consulting Who we are Equation Consulting

More information

CancerLinQ Data Quality Management Policies

CancerLinQ Data Quality Management Policies CancerLinQ Data Quality Management Policies I. Introduction CancerLinQ is committed to conquering cancer through appropriate, secure and ethical usage of health information entrusted to the CancerLinQ

More information

HIPAA Privacy and Security Rules: A Refresher. Marilyn Freeman, RHIA California Area HIPAA Coordinator California Area HIM Consultant

HIPAA Privacy and Security Rules: A Refresher. Marilyn Freeman, RHIA California Area HIPAA Coordinator California Area HIM Consultant HIPAA Privacy and Security Rules: A Refresher Marilyn Freeman, RHIA California Area HIPAA Coordinator California Area HIM Consultant Objectives Provide overview of Health insurance Portability and Accountability

More information

HIPAA-G04 Limited Data Set and Data Use Agreement Guidance

HIPAA-G04 Limited Data Set and Data Use Agreement Guidance HIPAA-G04 Limited Data Set and Data Use Agreement Guidance GUIDANCE CONTENTS Scope Reason for the Guidance Guidance Statement Definitions ADDITIONAL DETAILS Additional Contacts Web Address Forms Related

More information

University of Cincinnati Limited HIPAA Glossary

University of Cincinnati Limited HIPAA Glossary University of Cincinnati Limited HIPAA Glossary ephi System A system that creates accesses, transmits or receives: 1) primary source ephi, 2) ephi critical for treatment, payment or health care operations

More information

IRB Month Investigator Meeting April 2014

IRB Month Investigator Meeting April 2014 April 2014 AUDITS TRENDS EMR COMPLIANCE PRACTICES EMR FEDERAL REGULATIONS MONITORING REGULATORY SECURITY THREATS ACADEMI CINA BREACHES REVIEW COMPUTING MOBILE CLOUD HIPAA CENTER OPERATION S RESEARCH C

More information

Foundation Working Group

Foundation Working Group Foundation Working Group Proposed Recommendations on De-identifying Information for Disclosure to Third Parties The Foundation Working Group (FWG) engaged in discussions around protecting privacy while

More information

Understanding De-identification, Limited Data Sets, Encryption and Data Masking under HIPAA/HITECH: Implementing Solutions and Tackling Challenges

Understanding De-identification, Limited Data Sets, Encryption and Data Masking under HIPAA/HITECH: Implementing Solutions and Tackling Challenges Understanding De-identification, Limited Data Sets, Encryption and Data Masking under HIPAA/HITECH: Implementing Solutions and Tackling Challenges Daniel C. Barth-Jones, M.P.H., Ph.D. Assistant Professor

More information

Children's Hospital, Boston (Draft Edition)

Children's Hospital, Boston (Draft Edition) Children's Hospital, Boston (Draft Edition) The Researcher's Guide to HIPAA Evervthing You Alwavs Wanted to Know About HIPAA But Were Afraid to Ask 1. What is HIPAA? 2. What is the Privacy Rule? 3. What

More information

Societal benefits vs. privacy: what distributed secure multi-party computation enable? Research ehelse 2015 21-22 April Oslo

Societal benefits vs. privacy: what distributed secure multi-party computation enable? Research ehelse 2015 21-22 April Oslo Privacy Societal benefits vs. privacy: what distributed secure multi-party computation enable? Research ehelse 2015 21-22 April Oslo Kassaye Yitbarek Yigzaw UiT The Arctic University of Norway Outline

More information

Everett School Employee Benefit Trust. Reportable Breach Notification Policy HIPAA HITECH Rules and Washington State Law

Everett School Employee Benefit Trust. Reportable Breach Notification Policy HIPAA HITECH Rules and Washington State Law Everett School Employee Benefit Trust Reportable Breach Notification Policy HIPAA HITECH Rules and Washington State Law Introduction The Everett School Employee Benefit Trust ( Trust ) adopts this policy

More information

North Shore LIJ Health System, Inc. Facility Name

North Shore LIJ Health System, Inc. Facility Name North Shore LIJ Health System, Inc. Facility Name POLICY TITLE: The Medical Record POLICY #: 200.10 Approval Date: 2/14/13 Effective Date: Prepared by: Elizabeth Lotito, HIM Project Manager ADMINISTRATIVE

More information

Memorandum. Factual Background

Memorandum. Factual Background Memorandum TO: FROM: SUBJECT: Chris Ianelli and Jill Mullan, ispecimen, Inc. Kristen Rosati and Ana Christian, Polsinelli, PC ispecimen Regulatory Compliance DATE: January 26, 2014 You have asked us to

More information

Health Insurance Portability & Accountability Act (HIPAA) Compliance Application

Health Insurance Portability & Accountability Act (HIPAA) Compliance Application Health Insurance Portability & Accountability Act (HIPAA) Compliance Application IRB Office 101 - Altru Psychiatry Center 860 S. Columbia Rd, Grand Forks, North Dakota 58201 Phone: (701) 780-6161 PROJECT

More information

Protecting Personal Health Information in Research: Understanding the HIPAA Privacy Rule

Protecting Personal Health Information in Research: Understanding the HIPAA Privacy Rule AA Privacy RuleP DEPARTMENT OF HE ALTH & HUMAN SERVICES USA Protecting Personal Health Information in Research: Understanding the HIPAA Privacy Rule NIH Publication Number 03-5388 The HI Protecting Personal

More information

University of Mississippi Medical Center Office of Integrity and Compliance

University of Mississippi Medical Center Office of Integrity and Compliance Office of Integrity and Effective Date: 2005 By: Committee 1.0 PURPOSE The purpose of this policy is to guide (UMMC) employees, who are involved with research, in obtaining an authorization for the use

More information

VENDOR / CONTRACTOR. Privacy Basics

VENDOR / CONTRACTOR. Privacy Basics VENDOR / CONTRACTOR Privacy Basics Introduction Premera s mission is to provide our customers with peace of mind about their healthcare. This requires that everyone who works with or for Premera (the Company

More information

Grand Rapids Medical Education Partners Mercy Health Saint Mary s Spectrum Health. Pam Jager, GRMEP Director of Education & Development

Grand Rapids Medical Education Partners Mercy Health Saint Mary s Spectrum Health. Pam Jager, GRMEP Director of Education & Development Grand Rapids Medical Education Partners Mercy Health Saint Mary s Spectrum Health Pam Jager, GRMEP Director of Education & Development To understand the requirements of the federal Health Information Portability

More information

HIPAA Compliance Issues and Mobile App Design

HIPAA Compliance Issues and Mobile App Design HIPAA Compliance Issues and Mobile App Design Washington, D.C. April 22, 2015 Presenter: Shannon Hartsfield Salimone, Holland & Knight LLP, Tallahassee and Jacksonville, Florida Agenda Whether HIPAA applies

More information

INDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS. I. Introduction 2. II. Definitions 3

INDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS. I. Introduction 2. II. Definitions 3 INDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS I. Introduction 2 II. Definitions 3 III. Program Oversight and Responsibilities 4 A. Structure B. Compliance Committee C.

More information

HIPAA PRIVACY POLICY FOR OPTICAL LABS TABLE OF CONTENTS. Exhibit B Notice of Privacy Practices pages B-1 to B-4

HIPAA PRIVACY POLICY FOR OPTICAL LABS TABLE OF CONTENTS. Exhibit B Notice of Privacy Practices pages B-1 to B-4 HIPAA PRIVACY POLICY FOR OPTICAL LABS TABLE OF CONTENTS HIPAA Privacy Policy pages 2 to 12 Exhibit A HIPAA Privacy Regulations pages A-1 to A-89 Exhibit B Notice of Privacy Practices pages B-1 to B-4 Exhibit

More information

Information Privacy and Security Program Title:

Information Privacy and Security Program Title: 1 Page: 1 of 5 I. PURPOSE: 1 The purpose of this standard is to identify and define the standards for implementing contracting provisions related to those individuals and organizations identified as Business

More information

Application for an Off-Site Tissue Banking Waiver at a Non-Profit or Academic Institution

Application for an Off-Site Tissue Banking Waiver at a Non-Profit or Academic Institution Application for an Off-Site Tissue Banking Waiver at a Non-Profit or Academic Institution INSTRUCTIONS This form may be filled in and saved using Adobe Reader version 7.0 or higher. The full version of

More information

New Guidance on De-Identification of Protected Health Information Released by Office of Civil Rights

New Guidance on De-Identification of Protected Health Information Released by Office of Civil Rights Health Care ADVISORY December 7, 2012 New Guidance on De-Identification of Protected Health Information Released by Office of Civil Rights On November 26, 2012, the United States Department of Health and

More information

HIPAA OVERVIEW ETSU 1

HIPAA OVERVIEW ETSU 1 HIPAA OVERVIEW ETSU 1 What is HIPAA? Health Insurance Portability and Accountability Act. 2 PURPOSE - TITLE II ADMINISTRATIVE SIMPLIFICATION To increase the efficiency and effectiveness of the entire health

More information

Guidance on De-identification of Protected Health Information November 26, 2012.

Guidance on De-identification of Protected Health Information November 26, 2012. Guidance Regarding Methods for De-identification of Protected Health Information in Accordance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule November 26, 2012 OCR gratefully

More information

BUSINESS ASSOCIATE AGREEMENT HIPAA Protected Health Information

BUSINESS ASSOCIATE AGREEMENT HIPAA Protected Health Information BUSINESS ASSOCIATE AGREEMENT HIPAA Protected Health Information I. PREAMBLE ( Covered Entity ) and ( Business Associate ) (jointly the Parties ) wish to enter into an Agreement to comply with the requirements

More information

HIPAA and Clinical Research

HIPAA and Clinical Research To Heal. To Teach. To Discover. HIPAA and Clinical Research 2011 Training Jennifer Edlind, UH Privacy Officer Ryan Terry, UH Information Security Officer 1 Agenda Research credentialing overview HIPAA

More information

Best Practice Guidelines for Managing the Disclosure of De-Identified Health Information

Best Practice Guidelines for Managing the Disclosure of De-Identified Health Information Best Practice Guidelines for Managing the Disclosure of De-Identified Health Information Prepared by the: Health System Use Technical Advisory Committee Data De-Identification Working Group October 2010

More information

Abstract. It s peace of mind knowing that we ve done everything that is possible to meet industry standards for de-identification. Dr.

Abstract. It s peace of mind knowing that we ve done everything that is possible to meet industry standards for de-identification. Dr. Abstract In this presentation I will discuss the adoption of the Privacy Analytics Risk Assessment Tool (PARAT) by the Institute for Clinical Evaluative Sciences (ICES), for the Ontario Cancer Data Linkage

More information

HIPAA Privacy & Breach Notification Training for System Administration Business Associates

HIPAA Privacy & Breach Notification Training for System Administration Business Associates HIPAA Privacy & Breach Notification Training for System Administration Business Associates Barbara M. Holthaus privacyofficer@utsystem.edu Office of General Counsel University of Texas System April 10,

More information

HIPAA 101: Privacy and Security Basics

HIPAA 101: Privacy and Security Basics HIPAA 101: Privacy and Security Basics Purpose This document provides important information about Kaiser Permanente policies and state and federal laws for protecting the privacy and security of individually

More information

UCSF and Data Contributor are hereinafter also referred to individually as Party and collectively as Parties.

UCSF and Data Contributor are hereinafter also referred to individually as Party and collectively as Parties. DATA USE AGREEMENT This Data Use Agreement ( Agreement ) is entered into by and between The Regents of the University of California, on behalf if its San Francisco campus ( UCSF or Data User ), and [full

More information

Section C: Data Use Agreement. Illinois Department of Healthcare and Family Services. And DATA USE AGREEMENT

Section C: Data Use Agreement. Illinois Department of Healthcare and Family Services. And DATA USE AGREEMENT Section C: Data Use Agreement Illinois Department of Healthcare and Family Services And DATA USE AGREEMENT This Data Use Agreement (the Agreement ) is effective as of (the Agreement Effective Date ) by

More information

Burn Model Systems National Data and Statistical Center STANDARD OPERATING PROCEDURE 601. Data Use Agreement

Burn Model Systems National Data and Statistical Center STANDARD OPERATING PROCEDURE 601. Data Use Agreement Data Use Agreement This Data Use Agreement (the Agreement ) is effective as of [month, day, year] (the Agreement Effective Date ) until [month, day, year] (the Agreement Termination Date ) by and between

More information

January 2003. Employers must be prepared for their obligations under the HIPAA Privacy Rules

January 2003. Employers must be prepared for their obligations under the HIPAA Privacy Rules Employer Sponsored Group Health Plans and the HIPAA Privacy Rules Employers must be prepared for their obligations under the HIPAA Privacy Rules January 2003 Bob Radecki KnowHIPAA.com HIPAA-COBRA-FMLA

More information

Degrees of De-identification of Clinical Research Data

Degrees of De-identification of Clinical Research Data Vol. 7, No. 11, November 2011 Can You Handle the Truth? Degrees of De-identification of Clinical Research Data By Jeanne M. Mattern Two sets of U.S. government regulations govern the protection of personal

More information

Statement of Policy. Reason for Policy

Statement of Policy. Reason for Policy Table of Contents Statement of Policy 2 Reason for Policy 2 HIPAA Liaison 2 Individuals and Entities Affected by Policy 2 Who Should Know Policy 3 Exclusions 3 Website Address for Policy 3 Definitions

More information

BUSINESS ASSOCIATE AGREEMENT BETWEEN LEWIS & CLARK COLLEGE AND ALLEGIANCE BENEFIT PLAN MANAGEMENT, INC. I. PREAMBLE

BUSINESS ASSOCIATE AGREEMENT BETWEEN LEWIS & CLARK COLLEGE AND ALLEGIANCE BENEFIT PLAN MANAGEMENT, INC. I. PREAMBLE BUSINESS ASSOCIATE AGREEMENT BETWEEN LEWIS & CLARK COLLEGE AND ALLEGIANCE BENEFIT PLAN MANAGEMENT, INC. I. PREAMBLE Lewis & Clark College and Allegiance Benefit Plan Management, Inc., (jointly the Parties

More information

IAPP Practical Privacy Series. Data Breach Hypothetical

IAPP Practical Privacy Series. Data Breach Hypothetical IAPP Practical Privacy Series Data Breach Hypothetical Presented by: Jennifer L. Rathburn, Partner, Quarles & Brady LLP Frances Wiet, CPO and Assistant General Counsel, Takeda Pharmaceuticals U.S.A., Inc.

More information

HIPAA Compliance for Students

HIPAA Compliance for Students HIPAA Compliance for Students The Health Insurance Portability and Accountability Act (HIPAA) was passed in 1996 by the United States Congress. It s intent was to help people obtain health insurance benefits

More information

Training, Resources and Networking for the E-Discovery Community

Training, Resources and Networking for the E-Discovery Community ACA Reporting and the HIPAA Omnibus Final Rule: Privacy and Security Requirements Doubly Strengthened New HIPAA Requirements and data reporting rules will affect healthcare providers, plans, many employers

More information

Virginia Commonwealth University Information Security Standard

Virginia Commonwealth University Information Security Standard Virginia Commonwealth University Information Security Standard Title: Scope: Data Classification Standard This document provides the classification requirements for all data generated, processed, stored,

More information

SJÖGREN S INTERNATIONAL COLLABORATIVE CLINICAL ALLIANCE (SICCA) BIOREPOSITORY AND DATA REGISTRY DATA MANAGEMENT PLAN

SJÖGREN S INTERNATIONAL COLLABORATIVE CLINICAL ALLIANCE (SICCA) BIOREPOSITORY AND DATA REGISTRY DATA MANAGEMENT PLAN 1 SJÖGREN S INTERNATIONAL COLLABORATIVE CLINICAL ALLIANCE (SICCA) BIOREPOSITORY AND DATA REGISTRY DATA MANAGEMENT PLAN 1. Database Overview The SICCA database includes the Clinical Database, the Biorepository

More information

HIPAA Privacy Manual

HIPAA Privacy Manual California State University HIPAA Privacy Manual Revised February 17, 2010 As prepared by Mercer Human Resource Consulting 2010 California State University The HIPAA Privacy Manual was drafted for the

More information

Principles and Best Practices for Sharing Data from Environmental Health Research: Challenges Associated with Data-Sharing: HIPAA De-identification

Principles and Best Practices for Sharing Data from Environmental Health Research: Challenges Associated with Data-Sharing: HIPAA De-identification Principles and Best Practices for Sharing Data from Environmental Health Research: Challenges Associated with Data-Sharing: HIPAA De-identification Daniel C. Barth-Jones, M.P.H., Ph.D Assistant Professor

More information

UPMC POLICY AND PROCEDURE MANUAL

UPMC POLICY AND PROCEDURE MANUAL UPMC POLICY AND PROCEDURE MANUAL POLICY: INDEX TITLE: HS-EC1611 Ethics & Compliance SUBJECT: Use and Disclosure of Protected Health Information (PHI) For Research Purposes Pursuant to the HIPAA Privacy

More information

HIPAA ephi Security Guidance for Researchers

HIPAA ephi Security Guidance for Researchers What is ephi? ephi stands for Electronic Protected Health Information (PHI). It is any PHI that is stored, accessed, transmitted or received electronically. 1 PHI under HIPAA means any information that

More information

8/3/2015. Integrating Behavioral Health and HIV Into Electronic Health Records Communities of Practice

8/3/2015. Integrating Behavioral Health and HIV Into Electronic Health Records Communities of Practice Integrating Behavioral Health and HIV Into Electronic Health Records Communities of Practice Monday, August 3, 2015 1 How to ask a question during the webinar If you dialed in to this webinar on your phone

More information

Presented by Jack Kolk President ACR 2 Solutions, Inc.

Presented by Jack Kolk President ACR 2 Solutions, Inc. HIPAA 102 : What you don t know about the new changes in the law can hurt you! Presented by Jack Kolk President ACR 2 Solutions, Inc. Todays Agenda: 1) Jack Kolk, CEO of ACR 2 Solutions a information security

More information

Health Insurance Portability and Accountability Policy 1.8.4

Health Insurance Portability and Accountability Policy 1.8.4 Health Insurance Portability and Accountability Policy 1.8.4 Appendix C Uses and Disclosures of PHI Procedures This Appendix covers procedures related to Uses and Disclosures of PHI. Disclosures to Law

More information

HIPAA and You The Basics

HIPAA and You The Basics HIPAA and You The Basics The Purpose of HIPAA Privacy Rules 1. Provide strong federal protections for privacy rights Ensure individual trust in the privacy and security of his or her health information

More information

Donna S. Sheperis, PhD, LPC, NCC, CCMHC, ACS Sue Sadik, PhD, LPC, NCC, BC-HSP Carl Sheperis, PhD, LPC, NCC, MAC, ACS

Donna S. Sheperis, PhD, LPC, NCC, CCMHC, ACS Sue Sadik, PhD, LPC, NCC, BC-HSP Carl Sheperis, PhD, LPC, NCC, MAC, ACS Donna S. Sheperis, PhD, LPC, NCC, CCMHC, ACS Sue Sadik, PhD, LPC, NCC, BC-HSP Carl Sheperis, PhD, LPC, NCC, MAC, ACS 1 DISCLAIMER Please review your own documentation with your attorney. This information

More information

HIPAA Data Use Agreement Policy R&G Template Updated for Omnibus Rule HIPAA DATE USE AGREEMENT 1

HIPAA Data Use Agreement Policy R&G Template Updated for Omnibus Rule HIPAA DATE USE AGREEMENT 1 HIPAA DATE USE AGREEMENT 1 This Data Use Agreement (the "Agreement") is effective as of (the "Agreement Effective Date") by and between ("Covered Entity") and ("Data User"). RECITALS WHEREAS, Covered Entity

More information

Health Data De-Identification by Dr. Khaled El Emam

Health Data De-Identification by Dr. Khaled El Emam RISK-BASED METHODOLOGY DEFENSIBLE COST-EFFECTIVE DE-IDENTIFICATION OPTIMAL STATISTICAL METHOD REPORTING RE-IDENTIFICATION BUSINESS ASSOCIATES COMPLIANCE HIPAA PHI REPORTING DATA SHARING REGULATORY UTILITY

More information

[Insert Name and Address of Data Recipient] Data Use Agreement. Dear :

[Insert Name and Address of Data Recipient] Data Use Agreement. Dear : [Insert Name and Address of Data Recipient] Re: Data Use Agreement Dear : The federal Health Insurance Portability and Accountability Act and the regulations promulgated thereunder (collectively referred

More information

Computer Security Incident Response Plan. Date of Approval: 23- FEB- 2015

Computer Security Incident Response Plan. Date of Approval: 23- FEB- 2015 Name of Approver: Mary Ann Blair Date of Approval: 23- FEB- 2015 Date of Review: 22- FEB- 2015 Effective Date: 23- FEB- 2015 Name of Reviewer: John Lerchey Table of Contents Table of Contents... 2 Introduction...

More information

POLIC ANDP CEDURE. t/ 1 vhi4. Email Encryption 11/10/2018. Effective: 12/9/2015. HIPAA/Privacy. Policy. Last New policy Revised: Policy# 11.

POLIC ANDP CEDURE. t/ 1 vhi4. Email Encryption 11/10/2018. Effective: 12/9/2015. HIPAA/Privacy. Policy. Last New policy Revised: Policy# 11. Page 11 of 8 ALCOHOL, DRUG AND POLIC ANDP E T AL HEAL TH SERVICES CEDURE Section Sub-section Policy Compliance HIPAA/Privacy Policy# 11.xxx Email Encryption Director's Approval -+~,..._._-~"---------------

More information

How To Protect Your Health Information Under Hiopaa

How To Protect Your Health Information Under Hiopaa Towards Unified Data Security Requirements for Human Research Susan Bouregy, Ph.D., CIP Chief HIPAA Privacy Officer Vice Chair, Human Subjects Committee Yale University susan.bouregy@yale.edu March 21,

More information

CREATIVE SOLUTIONS IN HEALTHCARE, INC. Privacy Policy

CREATIVE SOLUTIONS IN HEALTHCARE, INC. Privacy Policy CREATIVE SOLUTIONS IN HEALTHCARE, INC. Privacy Policy Amended as of February 12, 2010 on the authority of the HIPAA Privacy Officer for Creative Solutions in Healthcare, Inc. TABLE OF CONTENTS ARTICLE

More information

Data Masking for HIPAA Compliance

Data Masking for HIPAA Compliance The Safe Harbor Method: Abstract The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule mandates the de-identification of specific types of Protected Health Information (PHI)

More information

TriageLogic Information Security Policy

TriageLogic Information Security Policy TriageLogic Information Security Policy What is HIPAA, and what information is protected by it? HIPAA, short for the United States Health Insurance Portability and Accountability Act, is a set of standards

More information

Privacy Committee. Privacy and Open Data Guideline. Guideline. Of South Australia. Version 1

Privacy Committee. Privacy and Open Data Guideline. Guideline. Of South Australia. Version 1 Privacy Committee Of South Australia Privacy and Open Data Guideline Guideline Version 1 Executive Officer Privacy Committee of South Australia c/o State Records of South Australia GPO Box 2343 ADELAIDE

More information

Dispelling the Myths Surrounding De-identification:

Dispelling the Myths Surrounding De-identification: Dispelling the Myths Surrounding De-identification: Anonymization Remains a Strong Tool for Protecting Privacy Ann Cavoukian, Ph.D. Information & Privacy Commissioner, Ontario, Canada Khaled El Emam, Ph.D.

More information

Data Security Considerations for Research

Data Security Considerations for Research Data Security Considerations for Research Institutional Review Board Annual Education May 8, 2012 1 PRIVACY vs. SECURITY What s the Difference?: PRIVACY Refers to WHAT is protected Health information about

More information

Business Associate Agreement

Business Associate Agreement Business Associate Agreement This Agreement is entered into as of ("Effective Date"), between ( Covered Entity ), and ( Business Associate ). RECITALS WHEREAS, Business Associate provides services on behalf

More information