Exempt Resource - Identifiable and List of Identifiers

Last revised: Feb. 20, 2023

Identifiable data refers to any information that would enable an investigator to readily ascertain the identity of an individual. Below is a list of identifiers. If you are collecting one or more of the variables listed below, you should select “yes” when asked if identifiable data will be collected. The collection of social security numbers, student records, including grades and assignments, may require additional approvals.

• Name
• Geographical subdivisions smaller than a state, including street address, city, county, precinct, zip code, and equivalent geocodes (note, the initial three digits of a zip code are not considered identifiable)
• Elements of dates (except year) director related to an individual, including birth date, admission date, discharge date, date of death, and single year of age over 89 and all elements of dates (including year) indicative of such age (note, such ages and elements may be aggregated into a single category of age 90+)
• Phone numbers
• Fax numbers
• Electronic mail address (email)
• Social security numbers
• Medical record numbers
• Account numbers
• Certificate/license numbers
• Vehicle identifiers and serial numbers, including license plate numbers
• Device identifiers and serial numbers
• Web Universal Resource Locators (URLs)
• Internet Protocol (IP) address numbers
• Biometric identifiers, including finger and voice prints (audio recording)
• Full face photographic images and any comparable images (video recording)
• Student record number or identification number
• Student grades or classroom assignments
• Username for online or computer access
• Any other unique identifying number, characteristic, or code (note this does not mean the unique code assigned by the investigator to code the data)

Anonymous data refers to data that were collected without identifiers that could link the data back to the individual. Anonymous data does not contain any information or linkage that would enable the identity of the individual to be revealed.

De-identified data refers to data where all personally identifiable information have been permanently removed, severing identifiers from the observations.

Coded data refers to data that are initially collected with individual identifiers, which are subsequently replaced with a code (letter, number, or combination that is unrelated to individually identifiable characteristics. A key to the code is maintained to allow the identifiable information to be linked back to the coded information.

Sensitive data refers to any data or information that, if disclosed, could have adverse consequences for the individual or damage their financial standing, employability, insurability, or reputation.