I didn't respond to the original message because the question was not clear to me.
When Susan wrote "Email address is listed in the reg as an identifier that must be removed from data being disclosed" was she referring to the requirement in section 164.514(b)(2)(i) that ennumerates the various identifiers that must be removed for PHI to be de-identified under the "safe harbor" method? If not, I'm not sure what else she meant by that statement. Susan, can you cite where else the Rule requires that email addresses be removed? If Susan was referring to 164.514 then we are talking about a disclsoure of de-identified information. Why would you be emailing an individual de- identified information about themselves? Since you are emailing the individual this would qualify as a permitted disclosure to the individual and therefore there is no need to de-identify the information in the first place! Please explain your situation better and please give specific citations as to where you think there are conflicts with the Privacy Rule. Otherwise I'm afraid I don't understand the question well enough to offer an opinion. Noel Chang -- Open WebMail Project (http://openwebmail.org) ---------- Original Message ----------- From: [EMAIL PROTECTED] To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]> Sent: Tue, 28 Jan 2003 20:08:32 -0700 Subject: RE: Is patient email address PHI? > I will go out on a limb with an unsubstantiated opinion because it > is late > > Only if the email also contained health information or some indictor > of health status - or - If they could infer by the name or address > of the sender the health status of the recipient. > > Would anyone out there agree with that? > > -----Original Message----- > From: Brousseau, Susan [mailto:[EMAIL PROTECTED]] > Sent: Tuesday, January 28, 2003 4:58 PM > To: WEDI SNIP Privacy Workgroup List > Subject: Is patient email address PHI? > > This seems picayune, but: Email address is listed in the reg as an > identifier that must be removed from data being disclosed. If we > email a patient, would addressing that email to their email address > be considered a violation of HIPAA? > > Thank you, > > Susan Brousseau > Business Analyst > > > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. > The discussions on this listserv therefore represent the views of > the individual participants, and do not necessarily represent the > views of the WEDI Board of Directors nor WEDI SNIP. If you wish to > receive an official opinion, post your question to the WEDI SNIP > Issues Database at http://snip.wedi.org/tracking/. These listservs > should not be used for commercial marketing purposes or discussion > of specific vendor products and services. 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If you have received > this > > communication in error, please notify us immediately by replying to > the > > message and deleting it from your computer. Thank you. > > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. > The discussions on this listserv therefore represent the views of > the individual participants, and do not necessarily represent the > views of the WEDI Board of Directors nor WEDI SNIP. If you wish to > receive an official opinion, post your question to the WEDI SNIP > Issues Database at http://snip.wedi.org/tracking/. These listservs > should not be used for commercial marketing purposes or discussion > of specific vendor products and services. They also are not > intended to be used as a forum for personal disagreements or > unprofessional communication at any time. > > You are currently subscribed to wedi-privacy as: > [EMAIL PROTECTED] To unsubscribe from this list, go to the > Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a > blank email to [EMAIL PROTECTED] If you > need to unsubscribe but your current email address is not the same > as the address subscribed to the list, please use the > Subscribe/Unsubscribe form at http://subscribe.wedi.org ------- End of Original Message ------- --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: archive@mail-archive.com To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
