This section relates to health information that is maintained by campus units which are not a part of the UC Davis Health System (UCDHS). UCDHS is a “covered entity” as defined by the Health Insurance Portability and Accountability Act (HIPAA), and has very specific legal requirements related to the “protected health information,” (PHI) it maintains. Campus units not affiliated with UCDHS need to be mindful about the protection of any health information maintained, but the laws that govern the protection will be the federal Family Educational Rights and Privacy Act (FERPA) or the California Information Practices Act (IPA).
Medical/Health Information means any information, whether oral or recorded in any form or medium, that (a) is created or received by a healthcare provider, health plan, public health authority, employer, life insurer, school or university or health care clearinghouse; and (b) relates to the past, present, or future physical or mental health or condition of an individual, or the past, present, or future payment for the provision of health care to an individual.
Medical information and health insurance information are elements identified in the Personally Identifiable Information (PII) section of this guide as having a high level of sensitivity, which means it requires the highest level of protection.
However, health information which has been de-identified, meaning all PII has been removed, would be much less sensitive, requiring a moderate level of protection. De-identification means that the following data elements must not be present:
- 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:
- 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.
- Currently, 036, 059, 063, 102, 203, 556, 592, 790, 821, 823, 830, 831, 878, 879, 884, 890, and 893 are all recorded as "000".
- 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;
- Telephone numbers;
- Fax numbers;
- Electronic mail addresses;
- Social security numbers;
- Medical record numbers;
- Health plan beneficiary numbers;
- Account numbers;
- Certificate/license numbers;
- Vehicle identifiers and serial numbers, including license plate numbers;
- Device identifiers and serial numbers;
- Web Universal Resource Locators (URLs);
- Internet Protocol (IP) address numbers;
- Biometric identifiers, including finger and voice prints;
- Full face photographic images and any comparable images; and
- Any other unique identifying number, characteristic, or code, except as permitted by the re-identification rules, below; and
- There is no actual knowledge that information could be used alone or in combination with other information to identify an individual who is a subject of the information.