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Beyond Safe Harbor: Risk of Exposing Location in De-Identified Clinical Data
Alfred J. Anzalone, Carol Reynolds Geary, and James C. McClay
The use of de-identified EHR data for clinical and translational research has increased significantly since the HIPAA Privacy Rule De-Identification standards went into effect -Inclusion of SDOH measures in de-identified research is increasing as well, which presents an inherent risk of re-identifying PHI (primarily location units smaller than the state) -Data warehouse architecture and institutional policies need to recognize the risk associated with providing multiple location-based indices -Research interests are secondary to privacy concerns throughout biomedical research, but particularly in de-identified research, which is intended to promote more secure access to EHR data while allowing for expedient access (fewer institutional barriers to entry)
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