Which Labels Map to PHI Exactly?
To map labels to PHI exactly, you should focus on the following AnyFinds and Sensitive Data Definitions (SDDs):
1. Core AnyFinds that Map to PHI
These are the built-in detectors that identify the most common HIPAA-regulated identifiers:
- Health Information: Specifically designed to find medical-related data.
- Social Security Number: A primary identifier under HIPAA.
- Date of Birth: Often used in combination with other data to establish PHI.
- Drivers License / Passport Number: Government-issued identifiers that are part of the 18 HIPAA identifiers.
- E-Mail Address / Personal Address / Telephone Number: Contact information that becomes PHI when linked to health data.
2. Healthcare-Specific Identifiers (Custom or SDD)
For a precise PHI mapping, you should also include these specific medical identifiers:
- Medical Record Number (MRN)
- Health Insurance Claim Number (HICN)
- ICD-9 / ICD-10 Codes: International Classification of Diseases codes used for billing and diagnosis.
- Insurance Numbers: Policy or group numbers.
3. The "Exact Mapping" Strategy: Using SDDs
HIPAA defines PHI as health information linked to an individual. To map this exactly in Spirion and avoid false positives (like a list of softball team members), you should use Sensitive Data Definitions (SDDs) to create "Contextual PHI" rules:
- Rule Example:
(Health Information OR ICD-10 Code) NEAR (Name OR SSN OR MRN) - Mapping: When this SDD is triggered, the playbook should apply the "PHI" or "Restricted - PHI" label.
Summary of Mapping:
Spirion Data Type | HIPAA Category | Recommended Label |
|---|---|---|
Health Information | Medical Records / Diagnosis | PHI |
SSN / MRN / HICN | Unique Identifiers | PHI - Restricted |
ICD-9 / ICD-10 | Clinical Codes | PHI |
Name + DOB + Address | Demographic PHI | PHI - Confidential |
Operational Tip
In your Governance Dashboard, you can create a specific view that aggregates all results from these specific Data Types and SDDs into a single "PHI Risk" trend. This enables you to trace exactly how much PHI is being discovered and labeled across your environment.