Keck HIPAA Policies for Sample Submission

The Keck Facility will not accept samples containing protected health information (PHI) or electronic protected health information (ePHI) that is covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Any individually identifiable health information associated with a sample must be removed by the user before the sample will be accepted. Data that is “individually identifiable” includes any of the 18 identifiers that could be used, either alone or in combination with other information, to identify an individual. These identifiers are:

  • Name
  • Address (all geographic subdivisions smaller than state, including streetaddress, city, county, or ZIP code)
  • All elements (except years) of dates related to an individual (including birthdate, admission date, discharge date, date of death, and exact age if over 89)
  • Telephone numbers
  • FAX number
  • Email address
  • Social Security number
  • Medical record number
  • Health plan beneficiary number
  • Account number
  • Certificate/license number
  • Vehicle identifiers and serial numbers, including license plate numbers
  • Device identifiers or serial numbers
  • Web URLs
  • IP address
  • Biometric identifiers, including finger or voice prints
  • Full-face photographic images and any comparable images
  • Any other unique identifying number, characteristic, or code

All of the above identifiers must be removed (de-identification) or sufficiently encoded (anonymization) by the user to prevent re-identification of an individual before samples will be accepted.