AhaBulb: Stuff Everyone Should Know · ahabulb.com/hipaa-deid-relatives
Under Safe Harbor, whose identifiers must be removed besides the patient's own?
Relatives, employers and household members.
- The patient's relatives, employers and household members ✔
- Nobody else's
- Only the treating doctor's
Why: Removing the patient's own name isn't enough. The 18 identifiers must also be removed for relatives, employers and household members, since they could point back to the patient.
Huh, didn't know that: Device serial numbers and web addresses (URLs) are also on the remove list.
Why did the whole household get de-identified? Because one person's HIPAA is a family affair.
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References
Answer: The patient's relatives, employers and household members. Removing the patient's own name isn't enough. The 18 identifiers must also be removed for relatives, employers and household members, since they could point back to the patient.
- 45 CFR 164.514 (eCFR) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.514
The following identifiers of the individual or of relatives, employers, or household members of the individual, are removed
Checked 2026-10-10.
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