Steps to Protect Against Privacy Loss
The committee recommended several steps the government can take to help safeguard private data:
• Data minimization. Obtain the least data necessary for the task. For example, if the goal is to study the spread of a disease, only the condition, date, and vague location (city or county) may suffice; the name or contact information of the patient may be unnecessary.
• Data anonymization. Where possible, replace identifying information with untraceable codes (such as a record number). But make sure those codes cannot be linked to another database that reveals sensitive data.
• Auditing. Record who has accessed data and when, both to help identify responsible parties in the event of a breach and to document the extent of damage.
• Security and controlled access. Adequately protect and control access to sensitive data.
• Training. Ensure that people accessing data understand what to protect and how to do so.
• Quality. Take into account the purpose for which data were collected, how they were stored, their age, and similar factors to determine the usefulness of the data.
• Restricted usage. As distinct from controlling access, review all proposed uses of the data to determine if those uses are consistent with the purpose for which the data were collected and the manner in which they were handled (validated, stored, controlled).
• Data left in place. If possible, leave data with the original owner or collector. This step helps guard against possible misuses of the data from expanded mission just because the data are available.
• Policy. Establish a clear policy for data privacy. Discourage violation of privacy policies.
