PHI Sensitive Data Definition (SDD) Example

To create a high-accuracy PHI (Protected Health Information) SDD, Spirion recommends you combine a Personal Identifier (who the person is) with a Medical Context (what their health status is).

Here is a practical example of PHI SDD logic designed to reduce false positives:

SDD Name: High-Confidence PHI (Identifier + Clinical Context)

The Logic Components:

  1. Primary Detector: AnyFind: Social Security Number (or AnyFind: Name)
  2. Operator: Near with Distance (100)
  3. Context Detector: Custom Dictionary: Clinical_Keywords (containing terms like Diagnosis, ICD-10, Patient, Treatment, Prognosis, Clinic)

The Logic String:

[AnyFind: Social Security Number] NEAR WITH DISTANCE (100) [Custom Dictionary: Clinical_Keywords]


Why this logic is effective:

  • Proximity (The "100" Rule): By setting a distance of 100 characters, you ensure the SSN and the medical term are logically related (e.g., in the same paragraph, form field, or spreadsheet row). An SSN on page 1 and the word "Patient" on page 10 will not trigger this rule.
  • Validation: Because it uses the AnyFind: Social Security Number, Spirion’s engine automatically performs checksum validation. This means a random 9-digit part number will not trigger the SDD, even if it's near a medical term.
  • Reduced Noise: A list of employee names and SSNs for payroll (which is PII, but not PHI) will not trigger this SDD because the clinical keywords are missing.


Advanced Variation: The "Triple-Match" PHI Rule

If you want to be even more specific (for example, for a "Restricted" classification), you can require 3 elements:

([AnyFind: Name] NEAR WITH DISTANCE (50) [AnyFind: Date of Birth]) REQUIRE [AnyFind: Health Information]

  • How it works: This requires a Name and DOB to be right next to each other (establishing a "Person") AND requires the built-in Health Information AnyFind to be present anywhere in the same file.

Implementation Steps

  1. Create the Dictionary: Go to Data Types -> Custom -> Dictionary and add your clinical terms.
  2. Build the SDD: Go to Data Types -> Sensitive Data Definitions -> New.
  3. Map to Playbook: Create a Playbook where the condition is Data Type = [Your New PHI SDD].
  4. Action: Set the action to "Classify: PHI" and "Notify: Privacy Team".

Operational Tip: Use this SDD to drive your Governance Dashboard. By reporting on this specific SDD, you can show leadership exactly where your highest-risk, "true" PHI resides, separate from general PII.