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National Institutes of Health HIPAA Privacy Rule - Information for Researchers
This website is currently in the process of being updated. For guidance on the HIPAA Privacy Rule in research, please see: https://www.hhs.gov/hipaa/for-professionals/special-topics/research/index.html
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Slide Presentation on the Privacy Rule and Research


Slide 18:
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Does “Unique Identifier” Include a
Re-identification Code?

  • A covered entity may assign a code to allow information de-identified under the Privacy Rule to be re-identified by the covered entity, as long as:
    • The code is not derived from or related to information about the individual.
    • The code is not otherwise capable of being translated to identify the individual. And
    • The covered entity does not use or disclose the code for any other purpose, and does not disclose the mechanism for re-identification.
  • Disclosure of a code or other means of record identification designed to enable coded (or otherwise de-identified information) to be re-identified is a disclosure of PHI. And
  • If de-identified information is re-identified, a covered entity must use or disclose such re-identified information in accordance with the Privacy Rule.

Department of Health and Human Services National Institutes of Health USAGov The HIPAA Privacy Rule