Identifiers that are obtained from Yale’s clinical system are considered to include health information based on the implicit understanding that to be listed in our clinical systems indicates that care was or will be provided.
At Yale then, research would be considered to involve PHI and thus be subject to HIPAA if all of the following conditions are met:
- The data includes any of the identifiers listed below AND
- Health Information AND
-
The data is created or received by a clinical department in YSM, YSN, Yale Health, the Psychology Clinics or any other covered entity.
PHI is considered individually identifiable if it includes one or more of the following identifiers:
- Names
- AII geographic subdivisions smaller than a state, including:
- street address
- city
- county
- precinct
- ZIP codes 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: (l) 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.
- Telephone numbers
- Fax numbers
- Email addresses
- Social Security numbers
- Medical record numbers
- Health plan beneficiary numbers
- Account numbers
- All elements of dates (except year) for dates related to an individual. including:
- birth date
- admission date
- discharge date
- date of death
- 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
- Certificate/license numbers
- Vehicle identifiers and serial numbers. including license plate numbers
- Device identifiers and serial numbers
- Web Universal Resource Loca101s (URLs)
- Internet Protocol (IP) address numbers
- Biometric identifiers. including finger and voice prints
- Full face photographic images and any comparable images
- Any other unique identifying nuntbers, characteristics or codes
