[ Tuesday, August 02, 2005 ]
De-identification of photographic PHI:
There's been a fairly lively discussion on the AHLA "HIT List" (the Health Information Technology listserv) recently about whether you can de-identify a photograph that is PHI: the traditional black bar across the eyes? Pixilation of the entire face? Blurring or blacking out all of the photo that's not specifically relevant to the PHI that needs to be shown? Obviously, if it would be impossible for someone to tell whose body is being shown, is it PHI (is it "individually identifiable" information)?
Two primary lines of comments came out. The first is that you should get an authorization from the individual, even if the photo is de-identified. There are probably non-HIPAA reasons for this as well, since individuals usually have the right to control the distribution of their own image; read the back of a sporting event ticket sometime. Also, Mark C. Lewis provided a link to this cautionary tale
: it's not just the face that makes a person identifiable. Something to keep in mind if you're addressing this.
Jeff [10:06 AM]
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