De-identification
The process of removing identifiers from PHI such that the resulting information is not individually identifiable health information.
1 min read · Last reviewed May 23, 2026
At a glance
- Category
- HIPAA & Privacy
- Primary sources
- 2
- Workspace handoff
- compliance binder →
Where this comes up
Privacy officers and practice managers handle this — patient rights requests, accounting of disclosures, BAA reviews with new vendors, breach risk assessments after an incident, and OCR responses when a complaint lands. The 60-day breach-notification clock starts at discovery, not at investigation close.
Full definition
What it is in practice
45 CFR 164.514(b) provides two methods: Safe Harbor (remove 18 enumerated identifiers) and Expert Determination (statistician confirms very low re-identification risk). De-identified data is outside HIPAA.
How it shows up in your practice
Document the de-identification method. Don't assume removing names is enough — the Safe Harbor list includes dates more granular than year, ZIP beyond first three digits, and several others.
Sources
- 45 CFR 164.502 — Uses and disclosures of PHIhttps://www.ecfr.gov/current/title-45/section-164.502
- HHS — HIPAA Privacy Rulehttps://www.hhs.gov/hipaa/for-professionals/privacy/index.html
Document de-identification methods in the Compliance Binder
Open compliance binder →Related terms
- HIPAA & PrivacyLimited Data SetPHI that excludes direct identifiers but may include city, state, ZIP, dates, and other quasi-identifiers; may be disclosed for research, public health, or healthcare operations under a Data Use Agreement.
- HIPAA & PrivacyPHI (Protected Health Information)Individually identifiable health information held or transmitted by a covered entity or its business associate, in any form.
- Compliance ProgramResearch and HIPAAHIPAA-authorized pathways for using or disclosing PHI for research, including authorization, IRB waiver, limited data sets with data use agreement, and decedent research.
D3rx is a healthcare-billing and compliance research aid maintained by D3rx Inc. Articles are drafted by an LLM (Anthropic Claude) against primary HHS, OCR, CMS, eCFR, NIST, and state-regulator publications, and reviewed for restraint and source fidelity by the D3rx team.
Reviewer status: a named credentialed reviewer (CHC, CHPC, or healthcare attorney) is being engaged. Until that engagement is finalized, this page does not claim credentialed review.
Related across the archive
- GlossaryLimited Data SetPHI that excludes direct identifiers but may include city, state, ZIP, dates, and other quasi-identifiers; may be disclosed for research, public health, or healthcare operations under a Data Use Agreement.
- GlossaryPHI (Protected Health Information)Individually identifiable health information held or transmitted by a covered entity or its business associate, in any form.
- GlossaryResearch and HIPAAHIPAA-authorized pathways for using or disclosing PHI for research, including authorization, IRB waiver, limited data sets with data use agreement, and decedent research.
- GlossaryAccounting of DisclosuresThe HIPAA right of an individual to receive a list of disclosures of their PHI made by a covered entity over the prior six years.
- GlossaryAmendment of PHIThe HIPAA right of an individual to request that a covered entity amend PHI in a designated record set.
- RegulationHIPAA Accounting of Disclosures (45 CFR 164.528)Individuals may request an accounting of disclosures of their PHI made by a covered entity in the prior six years, with a defined list of exclusions.
- BillingBusiness Associate Agreement Checklist for Small PracticesA working checklist for small practices to identify which vendors need a Business Associate Agreement, what clauses the BAA must contain, and how to track them.
- SRAHIPAA Patient Right of Access: A Small-Practice WalkthroughHow 45 CFR 164.524 governs patient access to their records, the 30-day rule and 30-day extension, the limited fees a practice may charge, and the OCR Right of Access Initiative.
This glossary entry is a research aid for billing and compliance staff. It does not provide legal, medical, or financial advice and does not replace counsel. References cited link to primary sources at HHS, OCR, CMS, eCFR, NIST, and the relevant payer or industry body.