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Policy Manual
HEALTH CARE
Standards Regarding Record Keeping of Health Matters

44-7-3.5
Uses and Disclosures of Protected Health Information:   Other Requirements

Policy The Department shall take the following procedures for de-identification and verification:
De-Identification Process

The Department shall ascertain that health information to be disclosed is not individually identifiable by

·          designating professional staff with experience in the use of generally accepted statistical and scientific principles and methods for rendering information not individually identifiable

·           removing crucial identifying information regarding the
 individual(s) involved, such as names, addresses, dates of
 birth or any number that has been assigned to the individual,
 or

·           assigning a code to allow de-identified information to be
 re-identified by the Department.

Verification Process

The Department shall obtain written, signed documentation from the person requesting the PHI when it is required as a condition of the disclosure.  A subpoena or other similar administrative process may satisfy this requirement.   For public officials, appropriate government letterhead is also required.

If the request for information is made in person, presenting official credentials or badges satisfies verification.

The verification requirements are met if the Department relies on the exercise of professional judgment or acts on a good faith belief in making a disclosure.

Connecticut Department of Children and Families              Effective Date:   April 14, 2003 (New)


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