Safe Harbour Anonymization

 

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Obfuscate PHI and More

Do you need to redact or disguise protected health information (PHI) or other personally identifiable information (PII)? And, can you do it in a way that:

  • is safe from hacking, or bypass (gleaning the information from other data)?
  • preserves the original column and field layouts (position, size data type)?
  • keeps the anonymized data looking real enough for testing purposes?
  • is convenient, simple, efficient, and affordable?
  • will comply with the HIPAA Safe Harbour rule?

With IRI FieldShield, other IRI Data Protector suite software products, or the IRI Voracity total data management platform, you can easily remove or otherwise obfuscate PII columns in databases and files. With IRI CellShield, you can do the same in Excel 2010-16 spreadsheets.

The masking method you choose determines the appearance of the anonymized fields, and the likelihood of recovering the original values. See this article for advice on method selection.

IRI's data masking functions in general (and below, field-level encryption in particular) apply to HITRUST CSF and, as shown below, the HIPAA Privacy Rule for covered entities and business associates:

45 CFR 164.312, Technical Safeguards

Implement technical policies and procedures to limit EPHI access to only "those persons or software programs that have been granted access rights. These systems must allow for unique user identification, emergency access, automatic logoff, and encryption and decryption.

With field-level control, you can use multiple encryption libraries and keys (pass phrases) for field-specific, need-to-know decryption entitlements.

* Transmission security, including two addressable specifications:

  1. Integrity controls -- security measures to ensure that electronically-transmitted PHI is not improperly modified without detection until disposed of, and.
  2. Encryption --  Designation of encryption as an addressable specification is a key departure from the proposed rule, which explicitly required encryption when using open networks. Covered entities now must determine how to protect EPHI "in a manner commensurate with the associated risk."

FieldShield makes encryption another option for field-level protection within tables and files, along with filtering, anonymization, and pseudonymization, while CellShield does the same in Excel. The CoSort SortCL program or various Hadoop masking engines deployed interchangeably in the Voracity platform do as well, and even while running high volume manipulations and reports against massive data sources.

* Hardware, software, and/or procedural methods for providing audit controls

Optional application statistics, and a query-ready XML audit log, record the job script and encryption libraries used to show what, when, how, and by whom the PHI field data was encrypted (and otherwise protected and/or transformed).

* Policies and procedures to protect EPHI from improper alteration or destruction to ensure data integrity. This integrity standard is coupled with one addressable implementation specification for a mechanism to corroborate that EPHI has not been altered or destroyed in an unauthorized manner.

Data that does not decrypt with the proper encryption key suggests that the decrypted field has been compromised. You can trace this through runtime statistics and audit logs that IRI software produces automatically. You can see when and how the file was processed for field encryption.

* Person or entity authentication, which requires the covered entity to implement procedures that verify that a person or entity seeking access to EPHI is the one claimed to be doing so.

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