skills/treatment-plans/references/privacy_governance.md
Last reviewed: 2026-07-23
Passing a template or script does not establish de-identification, HIPAA compliance, authorization, lawful disclosure, security, or appropriate retention. Those determinations belong to qualified local privacy, security, legal, and records personnel.
Use exactly one package-wide classification:
synthetic — invented records with no relationship to a real person.deidentified_qualified_review — patient-derived information that a qualified reviewer has approved under the applicable method and context.real_patient_minimum_necessary — identifiable or potentially identifiable data handled only in an authorized local environment.Never relabel real data as synthetic. Hashing, pseudonymization, redaction of obvious fields, using a patient code, or removing direct identifiers does not by itself make data de-identified.
HHS describes two HIPAA Privacy Rule methods:
This skill performs neither method. Free text, dates, geography, rare combinations, longitudinal patterns, and other contextual information can retain identification risk. HHS specifically notes that clinical narratives are information-rich and may allow identification.
For patient-derived material:
Do not place a de-identification analysis or patient-derived examples in this repository.
HHS states that the HIPAA minimum necessary standard generally requires reasonable steps to limit uses, disclosures, and requests for protected health information, while identifying exceptions including disclosures to or requests by a healthcare provider for treatment.
This skill does not decide whether an exception applies. As a conservative process safeguard, always minimize what enters the package and follow the institution's current role-based access and disclosure policies.
Record:
Before any real-patient package is opened:
If any confirmation is absent, use synthetic templates and stop before reading values.
Prefer discrete identifiers, enums, dates, booleans, role labels, and source references. Use bounded clinician-authored text only where exact transcription is necessary.
Avoid:
The generic subject_ref must be a locally controlled pseudonymous reference. It is not proof of de-identification.
Bundled scripts must not echo clinical values. Reports are limited to:
Do not run scripts with shell tracing. Do not redirect reports to shared logs. Review local command history policies before working with sensitive paths.
The scripts:
These are defense-in-depth controls, not privacy determinations.
If accidental disclosure, unauthorized access, or suspected mishandling occurs:
HHS OCR breach reporting sources are listed in source_ledger.md. The skill does not file reports.