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HHS OCR guidance on de-identification (2012): hashed codes (HHS OCR, Guidance Regarding Methods for De-identification of PHI, 26 November 2012, section 3.5)

A plain hash of a patient identifier is itself an identifier under Safe Harbor; only a keyed code that meets paragraph (c) may stay.

Dated 17 Oct 2026Source checked 17 Oct 2026Basis: primary text

In the source's own words
“For instance, a code derived from a secure hash function without a secret key (e.g., “salt”) would be considered an identifying element. This is because the resulting value would be susceptible to compromise by the recipient of such data.”
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