Skip to Content

Submissions :: Protocol review process :: Expedited/Exempt Review :: Identifiers

Indentifiers

An identifier is any data that can either directly identify an individual or link an individual to their identity.  The list below is the generally accepted list for SBS studies; HIPAA regulations also provide a list of what is considered an identifier when working with medical records. The presence of an identifier can be an important part in determining the level of risk in a study. An anonymous study is a study where identifiers are not collected and/or not linked to participants’ identity.  If participant identifiers are collected, it is important that the data and identifiers are kept confidential, are appropriately stored, and are destroyed when no longer needed.

  • Name: this includes any part of the name and/or initials; for some research, this might also be an internet screen name.

  • Information that might locate a person:

    • Street address

    • Phone numbers (home, office, cell, etc)

    • Email addresses (personal, business, etc)

    • Place of employment

    • IP address

    • Vehicle IDs

    • Personal websites (blogs, individually owned URL, etc)

  • Identifying numbers:

    • Social Security number (full or partial)

    • Date of birth (Please note that the full date is an identifier; however, if you want to collect an individual’s age, year of birth, and/or month of birth, this information is not considered an identifier.)

    • Individual account numbers (credit cards, banks accounts, etc)

    • Medical record numbers

    • Student record numbers

    • Driver’s license number

    • Employee identification number

    • Individualized account login information (login id, passwords, etc)

  • Photos, Video recordings, Audio recordings: unless a person’s voice and/or image are disguised, the Board considers these data as identifiable. 

  • Other:

    • Journal entries or personal writings where descriptions can be linked back to an individual

    • Transcripts where information discussed can be linked back to an individual

HIPAA Identifiers:

  1. Names;

  2. All geographical 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: (1) The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and (2) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.

  3. 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;

  4. Phone numbers;

  5. Fax numbers;

  6. Electronic mail addresses;

  7. Social Security numbers;

  8. Medical record numbers;

  9. Health plan beneficiary numbers;

  10. Account numbers;

  11. Certificate/license numbers;

  12. Vehicle identifiers and serial numbers, including license plate numbers;

  13. Device identifiers and serial numbers;

  14. Web Universal Resource Locators (URLs);

  15. Internet Protocol (IP) address numbers;

  16. Biometric identifiers, including finger and voice prints;

  17. Full face photographic images and any comparable images; and

  18. Any other unique identifying number, characteristic, or code (note this does not mean the unique code assigned by the investigator to code the data)

Previous :: Minimal risk
Next :: Expedited protocols