Formal determination

In its summary of the HIPAA privacy rule, the US Department of Health & Human Services says there are two ways to de-identify data to satisfy HIPAA regulations. One is to remove certain types of identifiers listed under the Safe Harbor provisions, and the other is “a formal determination by a qualified statistician” that the data “neither identifies nor provides a reasonable basis to identify an individual.”

Data is often useless, either for academic research or commercial application, without some of the fields listed under the Safe Harbor provisions. In that case formal determination is the only way to comply with HIPAA and retain the usefulness of the data.

We can help. We are qualified statisticians with years of experience providing expert determinations for clients needing to de-identify data to satisfy HIPAA. We will work with you to understand your needs and priorities regarding your data, and to create a set of deidentification procedures that meet your business or scientific needs while protecting the privacy of individuals. Once this is done, we will provide you with a report containing recommended procedures and an expert determination of the effectiveness of these procedures.

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