Developers and HIPAA

De-identification of individuals' information

Is there any limitation on a covered entity's de-identification of PHI or use of de-identified information? For example, may a covered entity de-identify information purely for the purposes of selling data as a service? Additionally, from a Privacy Rule perspective (i.e., not considering state law or contractual considerations), are there any restrictions on a business associate using or disclosing the de-identified ...more »

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Who are your customers? Check all that apply : Patients/Individuals/Consumers

What is your organization? : Attorney/other compliance consultant

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3 votes
3 up votes
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Answered Questions

Developers and HIPAA

Sale of Data Collected by a Consumer Targeted App

We are not a covered entity or business associate. We are developing a direct-to-consumer app that tracks medication adherence. We want to de-identify the information the app collects to sell to third parties. Do we follow the same HIPAA de-identification processes that a covered entity or business associate would follow?

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Who are your customers? Check all that apply : General Public, Patients/Individuals/Consumers

What is your organization? : Small company, Software developer not specific to health care

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3 votes
3 up votes
0 down votes
Answered Questions

Developers and HIPAA

When is PHI de-identified?

We have developed a platform to facilitate the scheduling of transport/rides for patients to provider appointments. The process works as follows. The provider logs into a secure site, to schedule a ride to an appointment for a patient. The platform, at the appropriate time, sends formation to a rider service provider (someone such as Lyft, Uber, etc..) to schedule the transport. The information provide the transport ...more »

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Who are your customers? Check all that apply : Business associates (operates on behalf of/provides service to health care provider/health plan, e.g., an EHR vendor), Health plans or health care providers

What is your organization? : Developer of Mhealth apps (not mobile medical apps), For profit, Attorney/other compliance consultant

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2 votes
2 up votes
0 down votes