It depends. Unless the institutional statistician or Defense Health Agency (DHA) Privacy Officer is a member of a Department of Defense (DOD) Institutional Review Board (IRB), they cannot be used to confirm that data is de-identified. The Health Insurance Portability and Accountability Act permits an institution to use an individual with the appropriate knowledge and experience in statistical principles/methodologies to de-identify data. However, for requests involving data managed by DHA (DHA data), a DOD IRB will make the final data determinations currently made by DHA data experts by using the Data Determination Guides (DDGs) as guidance and documentation of the decision. The DOD IRB may use an institutional statistician or Privacy Officer to assist in determining whether data is de-identified, but the DOD IRB must indicate its final data determination by documenting the determination in the DDG.