Records / Laws and rulings

HIPAA Privacy Rule: re-identification codes (45 CFR 164.514(c))

A record key may survive de-identification only if it is not derived from the person's data and the key to reverse it never leaves the covered entity.

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

In the source's own words
“A covered entity may assign a code or other means of record identification to allow information de-identified under this section to be re-identified by the covered entity, provided that: (1) Derivation. The code or other means of record identification is not derived from or related to information about the individual and is not otherwise capable of being translated so as to identify the individual; and (2) Security. The covered entity does not use or disclose the code or other means of record identification for any other purpose, and does not disclose the mechanism for re-identification.”
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