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​​​​​List of HIPAA Identifiers

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 specifies a number of elements in health data that are considered identifiers. If any are present, the health information cannot be released without patient authorization. Such data can be released for research purposes with approval of a waiver of patient authorization from an Institutional Review Board (IRB). For DHCS identifiable data the IRB is the Committee for the Protection of Human Subjects (https://www.chhs.ca.gov/cphs/​)

The following are considered identifiers under the HIPAA safe harbor rule:

  1. ​Names;
  2. 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 i​nitial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
  3. 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;
  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; and
  18. Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c)​

For more information, please see the Guidance Regarding Methods for De-identification of Protected Health Information in Accordance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.

Last modified date: 8/8/2022 11:01 AM