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the investigator could also use the index to provide an intuitive measure of the risk of identification. for instance, a composite that indicates that all patients are matched at a probability of 99% might be considered too high-risk for use in data sharing. in contrast, an index with a 99% match for 100 subjects would indicate that all 100 subjects are likely to be the same. thus, this index could be used as the basis for a policy to restrict data sharing.
the “dark index” application on the dun & bradstreet’s data universal client (d&bc duc) uses a large number of personal, demographic, and economic characteristics (or “dark indices”) to associate and match potential buyers and sellers to each other.
the privacy rule does not limit the disclosure of records that have been de-identified. however, a covered entity may allow restricted access to the records of the de-identified individual or to other records that contain the same data as the de-identified records, subject to additional requirements. covered entities may permit such information to be disclosed to specified individuals or classes of individuals for specified purposes. furthermore, certain entities, for example federal, state, or local governments, may lawfully disclose de-identified records to another party or entity for the purpose of performing an audit or inspection. finally, in some cases, a covered entity may permit a party or entity that has contracted with the covered entity to access and disclose de-identified records with a limited set of individuals. for example, the covered entity may allow an audit to be conducted by a fiscal agent that is required to perform audits of a business’s financial records. in this case, the audit would be conducted by the entity or person to which the covered entity is required to permit access. 32 for example, in this type of setting, the covered entity would specify the individuals and classes of individuals with whom the audit is to be conducted and the purposes for which the records will be used. the covered entity would also specify the information to be disclosed, such as the time period and nature of the audit, and the information to be retained, such as identifying numbers or other codes. the disclosure of an individual’s records to an auditor is usually lawful only to the extent that the individual consents to such a disclosure or the auditor is otherwise authorized to review the individual’s records by law. 81555fee3f

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