HIPAA Compliance
HIPAA Compliance

De-Identified Data: Understanding HIPAA's 18 Identifier Rule

May 28, 2025

Managing patient data securely is a significant concern for healthcare providers. With regulations like HIPAA, understanding how to work with de-identified data becomes all the more important. Let's explore how the HIPAA's 18 Identifier Rule helps ensure patient privacy while still allowing the valuable use of data in healthcare.

What Exactly Is De-Identified Data?

De-identified data is essentially information that has been stripped of personal identifiers, making it difficult, if not impossible, to link back to an individual. This is particularly important in healthcare, where sensitive personal health information (PHI) is involved. De-identifying data allows researchers and healthcare providers to use and share information for studies, analytics, and improvements in patient care without compromising privacy.

Why is this important? Well, imagine trying to improve treatment protocols without access to patient data. It would be like trying to solve a puzzle without all the pieces. De-identified data gives healthcare professionals the tools they need without risking patient confidentiality.

The 18 Identifier Rule: A Quick Rundown

So, what makes data truly de-identified according to HIPAA? The 18 Identifier Rule is a checklist of sorts. It specifies the types of information that must be removed to consider data de-identified. These identifiers include:

  • Names
  • All geographic subdivisions smaller than a state
  • All elements of dates (except year) for dates directly related to an individual
  • Phone numbers
  • Fax numbers
  • Email addresses
  • Social Security numbers
  • Medical record numbers
  • Health plan beneficiary numbers
  • Account numbers
  • Certificate/license numbers
  • Vehicle identifiers and serial numbers, including license plate numbers
  • Device identifiers and serial numbers
  • Web Universal Resource Locators (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 number, characteristic, or code

By removing or coding these identifiers, data can be shared and analyzed without violating HIPAA rules. Now, let’s break down some of these identifiers to understand why they’re important and how they can be managed.

Names and Geographic Information

Names are probably the most obvious identifier. They’re unique to individuals and can easily connect data back to a person. The same goes for geographic information, which is why any location data smaller than a state level is considered an identifier. This means no street addresses, city names, or even zip codes can be included.

To manage this, healthcare organizations often use coding systems or pseudonyms. This allows them to maintain some level of organization without exposing personal details. For example, a patient might be assigned a code or a pseudonym that only the healthcare provider knows how to trace back to the original individual.

Dates and Contact Information

Dates are trickier. You can’t use birthdates, admission dates, or any specific date associated with a person, except for the year. This is because dates can often be triangulated with other data to identify someone.

Contact information, such as phone numbers and email addresses, is also on the chopping block. This makes sense, given how connected we are through these means. Imagine receiving a call from someone claiming to have your health information; it’s a breach of privacy waiting to happen.

Social Security and Medical Record Numbers

Social Security numbers are a no-brainer. They are unique to each person and are often used in identity verification. Medical record numbers are similar in that they uniquely identify a patient's health record, which could easily link back to the individual if not properly de-identified.

To handle this, organizations might use encryption or generate random identifiers that are used internally and don’t have any real-world connection to the patient.

Biometric and Photographic Information

Biometric identifiers, like fingerprints or voice prints, and full-face photographs are other types of data that can easily pinpoint an individual. These are used for security and identification, so their inclusion in any dataset would be counterproductive to de-identification efforts.

For example, when healthcare providers are developing AI models that use facial recognition to diagnose conditions, they must ensure that any images used are not linked to patient identities outside of the research environment.

Feather's Role in De-Identified Data

When it comes to handling de-identified data, Feather can be an invaluable tool. We’ve designed Feather to help with the heavy lifting of compliance. For instance, by using our AI, healthcare providers can automate the removal of these 18 identifiers, ensuring that their data is HIPAA-compliant while still enabling them to derive meaningful insights.

Feather can also help with organizing and summarizing clinical notes in a way that maintains patient privacy, allowing healthcare professionals to focus more on care rather than on administrative tasks.

Why De-Identification Matters

It might seem like a lot of effort to de-identify data, but the benefits are substantial. De-identified data allows for:

  • Research and studies that can lead to medical breakthroughs
  • Improvement in healthcare services and treatment protocols
  • Training of AI models that can assist in diagnostics and treatment planning
  • Sharing information across platforms and organizations without compromising privacy

By ensuring data is de-identified, organizations can contribute to the broader healthcare community without risking patient trust or violating regulations.

Challenges in De-Identifying Data

Of course, de-identifying data isn’t without its challenges. One of the biggest hurdles is ensuring that the data remains useful after de-identification. It’s a balancing act between removing enough information to protect privacy and retaining enough to make the data valuable.

Another challenge is the risk of re-identification. Even with the removal of identifiers, datasets can sometimes be combined with other data sources to re-identify individuals. This requires ongoing vigilance and sometimes even legal agreements to prevent unauthorized data sharing.

Tips for Effective De-Identification

Here are some tips to ensure effective de-identification:

  • Regularly review and update de-identification practices to align with current standards and regulations.
  • Use data masking techniques to hide sensitive data while keeping the dataset functional.
  • Implement strong access controls to ensure only authorized personnel can access de-identified data.
  • Utilize tools like Feather to automate de-identification processes and maintain compliance effortlessly.

By following these practices, healthcare organizations can ensure they’re making the most of their data without compromising patient privacy.

How Feather Fits into the Picture

With Feather, we aim to simplify compliance with HIPAA’s strict requirements while enhancing productivity. Our AI-powered tools help healthcare professionals by summarizing clinical notes, automating admin work, and securely storing documents. By ensuring that data is de-identified and compliant, Feather allows healthcare providers to focus on what truly matters: patient care.

Whether you’re a small clinic or a large hospital, Feather offers a privacy-first, audit-friendly platform that can help you handle sensitive data securely and efficiently.

Final Thoughts

Understanding and implementing HIPAA’s 18 Identifier Rule for de-identified data is critical for healthcare providers. It allows the use of valuable data while ensuring patient privacy is never compromised. By utilizing tools like Feather, healthcare professionals can streamline compliance processes, eliminate busywork, and focus more on delivering quality patient care.

Feather is a team of healthcare professionals, engineers, and AI researchers with over a decade of experience building secure, privacy-first products. With deep knowledge of HIPAA, data compliance, and clinical workflows, the team is focused on helping healthcare providers use AI safely and effectively to reduce admin burden and improve patient outcomes.

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