This turned out to be something of a tangent, since we already have our group de-identification plan (#73<https://informatics.gpcnetwork.org/trac/Project/ticket/73>), but FWIW...
The relevant part of the HERON IRB protocol revised for 2011-2012<https://informatics.kumc.edu/work/attachment/wiki/HERON/HERON_Repository_HSC_IRB_Protocolv2_1final.pdf> starts around page 6: HIPAA Identifiers: We will be transforming identified data into a form that addresses all of the 18 de- identification criteria. We will shift all in the EMR 1–365 days into the past; the shift is different across records but constant within the records of each patient, thereby allowing temporal analyses such as the development of adverse effects after a drug. We have listed the identifiers specified by HIPAA and whether they will be included in our data sources and the general i2b2 repository. While de-identified, we will be requesting that investigators treat released data with the same sensitivity as a limited data set. It continues for another page or two. -- Dan
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