Law360: "HHS Data-Scrubbing Guidance Backs Strict Privacy Definitions"

Clarifying the types of data that need to be removed from data sets can also help companies maximize the value of the information that they hold as the value of and ability to use this data for research and public health purposes increases, Foley Hoag LLP security and privacy practice co-chair Colin Zick added.

"The guidance answers discrete questions that people have come across in operational circumstances, like can you list parts of a ZIP code," he said. "The answers to these questions could help companies get more use of the de-identified data. For example, if they realize that they can use part of a ZIP code, they might be able to further narrow down their data set instead of completely eliminating that factor."