Re:Algorithm can pick out almost any American in supposedly ...
by dwild on Wednesday July 24, 2019 @01:47PM
(#20517679)
Theses are pretty good ways to anonymize theses fields, but they are still just good if only that field is used.
Let say that you got 20,000 inhabitants, you'll only need about 14 fields that are binary, much less fields if they are not binary (which is quite likely to happen). You'll most likely already got the gender... Even if you limit the age to 10 possible values, that's equivalent to 3 binary fields!
Source: Pages 96-97 of the combined legislation, available at: https://www.hhs.gov/hipaa/for-professionals/privacy/laws-reg...
You are allowed to roll your own de-identification method, as long as the person doing so is an expert on statistics and de-identification and they document their analysis of why their method is sound. To my knowledge, most entities use the "safe harbor" approach of wiping any data in the legislated blacklist of dimensions.