Yes, it would. However, the image still counts as an identifier from which it would be possible to identify an individual and therefore the image should be classed as PHI. Furthermore, if the image is shared with a colleague who is not a member of the same covered entity´s workforce (i.e., a doctor in a different hospital), it may be necessary to sign a Business Associate Agreement before the image is shared to ensure the image remains protected while in another entity´s possession.