Closed jimduff-usds closed 6 months ago
From experience at my previous company, ordering_provider info IS NOT PII
Looking through https://github.com/CDCgov/prime-data-hub/pull/821/commits/cbb682d6558eebd374d4f18fe1a42579a2ad5031, here are the fields that are currently flagged as PII that I don't think are PII. I didn't see any flagged as NOT PII that should be reversed.
ordering_provider_city ordering_provider_phone_number ordering_provider_street ordering_provider_street2 patient_occupation patient_suffix
@jimduff-usds let me know if you have any questions
Let me know if you need another review!
@jlusds - I think I was misinterpreting the guidance, regarding the orderingprovider* fields. The guidance says,
The following additional demographic data elements should also be collected and reported to state or local public health departments but these data will not be collected by CDC or the Secretary’s designee. State and local privacy standards apply to the collection of these data elements. (Note: additional data elements may be requested by state, local or federal health departments at any time.)
1. Patient name (Last name, First name, Middle Initial)
2. Patient street address
3. Patient phone number with area code
4. Patient date of birth
5. Ordering provider address
6. Ordering provider phone number
Since the first 4 are PII, I assumed the last two are PII as well, but it actually doesn't say that. So I agree with you - let's make orderingprovider* stuff to be non-PII.
I disagree on patient_occupation and patient_suffix:
I think patient_occupation could be PII, if you are in a very narrow job category. FWIW, I don't think anyone is sending us patient_occupation, so its kinda moot anyway.
And the patient_suffix is part of the patient name, so I do think its PII.
Thanks for the additional detail! I'm fine making occupation and suffix PII
Is this done?
@jimduff-usds looks like you and James were working on this. Is this still an open issue?
Review every field in covid-19.schema, and decide if our PII designations are correct.
If no pii designation is present, then PII = false, that is, the field is NOT considered to be PII.
In particular, what about ordering_provider info - are they protected as well?
Key relevant document is : https://www.hhs.gov/sites/default/files/covid-19-laboratory-data-reporting-guidance.pdf