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                              FAQ
                              2085-If a CSP receives and maintains only information that has been de-identified in accordance with the HIPAA Privacy Rule, is it is a business associate?


    

    

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If a CSP receives and maintains only information that has been de-identified in accordance with the HIPAA Privacy Rule, is it is a business associate?








  
  
    

  
      





Answer:
No. A CSP is not a business associate if it receives and maintains (e.g., to process and/or store) only information de-identified following the processes required by the Privacy Rule.  The Privacy Rule does not restrict the use or disclosure of de-identified information, nor does the Security Rule require that safeguards be applied to de-identified information, as the information is not considered protected health information. See the OCR guidance on de-identification for more information.[1]
[1] See http://www.hhs.gov/hipaa/for-professionals/privacy/special-topics/de-identification/.

                    
  


Content created by Office for Civil Rights (OCR) Content last reviewed October 6, 2016Back to top
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