Thanks for the reply. I will concede or defer to you in regards to PHI and HIPAA... it seems the philosophy behind HIPAA/PHI is very different than PII or GDPR. HIPPA is prescriptive. PII/GDPR are principle-based. HIPAA, it seems, has some text that it's not PHI if the risk is "very small" based on the opinion of someone with statistical expertise documents that it could be de-identified OR if the person avoids an explicit list of 18 things that it cares about (see items (A) through (R) on page 96 of
https://www.hhs.gov/sites/default/files/ocr/privacy/hipaa/ad... ).
One of the first 17 things might be a surrogate key ("account number") in one's system but if you look through the others, the rest are things like name, SSN, biometrics, IP#s, etc, which are definitely not surrogate keys.
The "OR" language makes the statistical expertise (and "principles" of privacy) irrelevant if you avoid the 18 things; that avoidance forms a "safe harbor" of sorts so you don't have to do any heavy thinking/lifting.
The 18th ("(R)") element of what is considered PHI does seem to refer to surrogate keys but in a manner which creates a clear carve-out/safe-harbor for them not being PHI. That 18th form of PHI is "Any other unique identifying
number, characteristic, or code, except as permitted by paragraph (c) of this section;"
But that paragraph (c) section seems indicate identifiers such as surrogate integer/guid keys kept within a system, as long as they are 1) not derived from an individual's information (ie like integer or UUID surrogate keys) and 2) which are maintained solely in the system are not considered as element-18-"R"-PHI:
"(c) Implementation specifications:
Re-identification. A covered entity may assign a code or other means of record identification to allow information de-identified under this section to be re-identified by the covered entity, provided that:
(1) Derivation. The code or other means of record identification is not derived from or related to information about the individual and is not otherwise capable of being
translated so as to identify the individual; and
(2) Security. The covered entity does not use or disclose the code or other means of record identification for any other purpose, and does not disclose the mechanism for re-
identification."
By my reading, a surrogate key maintained within a system is thus clearly not PHI under HIPAA. I never looked at the details of HIPAA until today since it hasn't applied much to my data and have been focused more on PII/GDPR. I appreciate you describing the context of your remarks.