RE: Proposal from Big Basin break out

On 2013-05-11 22:49, Shane Wiley wrote:
> Kevin,
> 
>  While the tri-state de-identification scheme does not dictate
> specific IP Address replacement guiderails, I believe the "reasonable"
> tenant is the one to focus on here. For example, if IP Address is
> replaced with Postal Code (5 digit, not 9 digit) then I believe most
> record sets would continue to be deemed de-identified. But let's say
> another team is looking only a hyper location of data subset and the
> record set contains only the de-identified ID (separate key from other
> systems) and the lat/long for that ID. With only these data points, a
> team can look at the frequency of events and geo-spacial clusters
> overtime, but would not have the means to reverse identify the data
> set as no side facts/data exist. It's this type of balance that is
> difficult to prescriptively outline upfront and why standards focus on
> principles and allow innovation to occur within those boundaries.

Dear Shane,

Before we go deeply into the details, I personally believe that the 
hashings both at the beginning and at the end of the de-identification 
process are much more important than any postal codes (even the 
four-digit two-character ones of my country of origin). What kind of 
hashes would be part of the proposal?

Moreover, I feel that the proposed scheme is lacking in any 
prescriptive power for the permitted uses. For the permitted uses I 
would feel much more comfortable with some guidance on both 
pseudonymisation and de-identification. The latter is easily achieved if 
we get to a consensus on de-identification in general.

Regards,

  Walter

Received on Saturday, 11 May 2013 20:56:09 UTC