Data Classification

Definitions:

Protected Health Information (PHI) - Any individually identifiable health information that is transmitted or maintained in any form or medium, including electronic, paper, or oral formats. PHI includes information related to an individual’s past, present, or future physical or mental health condition, the provision of healthcare, or payment for healthcare services that identifies the individual or can reasonably be used to do so.

Limited Dataset - includes specific data elements but excludes direct identifiers and is pursuant to a data use agreement or regulatory allowable disclosures.

De-identified - absence of all identifiers of an individual including metadata. De-identification of PHI must comply with the HIPAA Privacy Rule’s Safe Harbor Method. Any other method for de-identification must be reviewed and approved by MUHC Information Security and MUHC System Privacy. De-identified PHI that has not been certified by MUHC Information Security retains the classification of DCL-4 and must be protected as if it were PHI until certification is obtained.

Data Classification Levels for MU Health contain the following as the most specific identifier:

• DCL - 4 - Any variation of the individual's name, contact information, driver's license number
• DCL - 3 - MRN, FIN, and or account number
• DCL - 2 - dates and/or zip codes only
• DCL - 1 - no identifiers

*Please note special permissions are required to store, disclose, or use social security numbers (SSN). This should be avoided when possible.

The following are considered identifiers according to HIPAA:

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 initial 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