The Tri Council Policy Statement (TCPS 2) defines identifiable information as follows:

Information that may reasonably be expected to identify an individual, alone or in combination with other available information, is considered identifiable information…

It goes on to further categorize identifiable information.

Examples of Identifiers

The US Government’s Health Insurance Portability and Accountability Act (HIPPA) contains useful examples of data items that constitute identifiers. These may be categorized as either direct or indirect identifiers. This categorization is not intended to be definitive but should be considered as guidance for investigators when considering the context of their own study data.

Identifier

Direct

Indirect

Study participant names

x

 

Medical practitioner names

 

x

Participant’s address (complete)

X

 

All geographical subdivisions smaller than a province/territory. (This includes partial postal codes).

 

x

All elements (except year) of dates related to an individual. Age and any element of date of birth for subjects over the age of 90.

 

x

Phone number

x

 

Fax number

x

 

Email addresses

x

 

Social Security numbers

X

 

Medical record and healthcare numbers

X

 

Health plan beneficiary numbers

x

 

Account numbers

x

 

Certificate/license numbers

x

 

Vehicle identifiers and serial numbers, including license plate numbers

x

 

Device identifiers and serial numbers

 

x

Web Universal Resource Locator (URL)

x

 

Internet Protocol (IP) address number

x

 

Biometric identifiers, including finger and voice prints

x

 

Full face photographic images and any comparable images

x