IRB Guidance - The 18 PHI Identifiers

In order for a record (or research data set) to be considered de-identified, each of the below identifiers must be removed. This is applicable to identifiers of the individual, or of relatives, employers, or household members of the individual.

1. Names
2. Geographic subdivisions that are smaller than a state if containing less than 20,000 people
   • This includes street address, city, county, precinct, and zip code (or equivalent geocodes).
   • The initial three digits of a zip code may be included if, according to the currently publicly available data from the Census Bureau, the geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people and the initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to “000.”
3. Dates
   • 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 (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older (as the 90 year old and over population is relatively small).
4. Telephone numbers
5. Fax numbers
6. E-mail addresses
7. Social security numbers
8. Medical record numbers
9. Health plan beneficiary numbers
10. Account numbers
11. Certificate or license numbers
12. Vehicle identifiers, serial numbers, and license plate numbers
13. Device identifiers and serial numbers
14. Internet Universal Resource Locators (URLs)
15. Computer Internet Protocol (IP) addresses
16. Biometric identifiers
17. Full-face photographs and comparable images
18. Any other unique identifying number, characteristic, or code