Access to Records Containing Individually Identifiable Health Information (IIHI) from Archives & Special Collections

Policy

In accordance with Columbia University (the “University”) policies governing data security and privacy, Archives & Special Collections provides access to records including Individually Identifiable Health Information (IIHI) in compliance with required safeguards for the privacy and security of such information.  The purpose of the policy is to safeguard the privacy of the information while making information available for research to the extent reasonable to do so.

This policy applies to anyone requesting access to records from Archives & Special Collections identified as potentially containing IIHI.  Note that access to these materials may be further restricted by the donors of the materials.

Definition of Individually Identifiable Health Information (IIHI)

Any information (including demographic and genetic information) that relates to (1) the past, present or future physical or mental health or condition of an individual, (2) the provision of Health Care to an individual or (3) the past, present or future payment for the provision of Health Care to an individual and either (a) identifies the individual or (b) with respect to which there is a reasonable basis to believe that the information can be used to identify the individual.  Additional information can be found here: Information Security Charter | University Policies

I. Access to Records Potentially Containing Individually Identifiable Health Information (IIHI) of Living People (records less than 100 years old with no proof of death such as published obituary or death certificate)

  • Columbia University affiliates (faculty, staff, or students) must submit the following to the Library contact page.
    • Attestation for Access to Records Potentially Containing Individually Identifiable Health Information (IIHI)
    • Documentation of approval from Columbia’s Institutional Review Board (IRB) including a summary of the specific requested data OR approval from the Department Administrator or Chair that includes a summary of the data request and the purpose of the data request.
  • External Requests.  External Requests will be reviewed by the Archives & Special Collections in addition to the Chief Privacy Officer.  Individuals requesting access to IIHI who are not faculty, staff or students at Columbia University shall submit the following information to the Library contact page.
    • Institutional approval (such as IRB approval or approval of Department Administrator or Chair) if the requestor is associated with an external organization. Note that if the requestor is not associated with an external organization, the Archives & Special Collections in consultation with the Chief Privacy Officer will review requests on a case-by-case basis.  Contact: https://library.cumc.columbia.edu/contact
    • A comprehensive data request including documentation to support the reason for the data request
    • A completed Attestation for Access to Records Potentially Containing Individually Identifiable Health Information (IIHI)

II. Access to Records Potentially Containing Individually Identifiable Health Information (IIHI) of Decedents

  • For access to the records containing the IIHI of individuals deceased more than 50 years (with proof of death such as published obituary or death certificate), or to records more than 100 years old, the Archives & Special Collections in consultation with the Chief Privacy Officer will review requests on a case-by-case basis.  Contact the Library contact page.
  • IIHI of an individual who has been deceased for less than 50 years (with proof of death such as published obituary or death certificate) requires Authorization from a legal representative of the decedent’s estate.  Contact:  the Library contact page.

III. Access to De-identified Health Information

  • When possible, disclosure of records containing IIHI of deceased or living individuals should be de-identified.  IIHI that has been de-identified requires the removal of 18 identifiers listed below, which removes any potential of re-identification.  De-identification requires Archives staff to redact the following identifiers before the data is provided to the requestor:
  1. Names (including initials)
  2. Demographic Information (street address, city, county or zip code)
  3. Dates (except year) (including DOB, date of admission, surgery etc.)
  4. Phone numbers;
  5. Fax numbers;
  6. Electronic mail addresses;
  7. Social Security numbers;
  8. Medical record numbers;
  9. Health plan beneficiary numbers;
  10. Account numbers;
  11. Certificate/license numbers;
  12. Vehicle identifiers and serial numbers, including license plate numbers;
  13. Device identifiers and serial numbers;
  14. Web Universal Resource Locators (URLs)
  15. Internet Protocol (IP) address numbers;
  16. Biometric identifiers, including finger and voice prints;
  17.  Full face photographic images and any comparable images; and

  18. Any other unique identifying number, characteristic, or code 

Archives & Special Collections reserves the right in certain cases to restrict access in part or in whole to individual health information found in its collections.