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Limited Data Set

A limited data set is PHI, but it is a more limited set of PHI without direct identifiers.

A limited data set may only contain:

  • City, state, zip code
  • Elements of date, and
  • Other numbers, characteristics, or codes not listed as direct identifiers

A limited data set excludes the following direct identifiers of the individual or of relatives, employers, or household members of the individual:

  • Names;
  • Postal address information, other than town or city, state, and zip code;
  • Telephone numbers;
  • Fax numbers;
  • Electronic mail addresses;
  • Social security numbers;
  • Medical record numbers;
  • Health plan beneficiary numbers;
  • Account numbers;
  • Certificate/license numbers;
  • Vehicle identifiers and serial numbers, including license plate numbers;
  • Device identifiers and serial numbers;
  • Web Universal Resource Locators (URLs);
  • Internet Protocol (IP) address numbers;
  • Biometric identifiers, including finger and voice prints; and,
  • Full face photographic images and any comparable images

If de-identification is not possible, a limited data set may be an alternative option.