Understanding the distinction between Personally Identifiable Information (PII) and Protected Health Information (PHI) is quite important for maintaining data privacy, regardless of the industry you operate in. Both terms refer to sensitive data, but their classifications and regulations differ significantly.

Let’s quickly clarify the differences between PII and PHI and take a look at their impact on common compliance frameworks like HIPAA, CMMC, and the FTC Safeguards Rule.

PII: A Broad Net for Personal Data

Personally Identifiable Information (PII) is a broad term referring to any data that can be used to identify a specific individual. This information can be directly identifiable, like a name or Social Security number, or indirectly identifiable when combined with other pieces of data. Here are some common examples of PII:

  • Name
  • Address (physical and email)
  • Phone number
  • Social Security number
  • Driver’s license number
  • Financial account information (credit card numbers, bank account details)
  • Medical record identifiers (not the medical details themselves)
  • Biometric data (fingerprints, facial recognition)
  • Online identifiers (IP addresses, device identifiers)

The specific types of PII considered sensitive can vary depending on the context and applicable regulations.

PHI: A Subset Focused on Health Data

Protected Health Information (PHI) is a specific subset of PII that relates to an individual’s past, present, or future physical or mental health condition. This data is strictly regulated by the Health Insurance Portability and Accountability Act (HIPAA). Here are some key examples of PHI:

  • Medical history (diagnoses, treatments, medications)
  • Mental health records
  • Genetic information
  • Test results (lab reports, X-rays)
  • Insurance claims

It’s important to understand that PII becomes PHI when it’s linked to an individual’s health information. For instance, your name and address alone are PII, but if attached to your medical records, they become PHI.

Compliance Frameworks and Data Protection

Both PII and PHI fall under the umbrella of data privacy, but their regulations differ. Here’s how these distinctions factor into key compliance frameworks:

  • CMMC (Cybersecurity Maturity Model Certification): This framework, designed for Department of Defense (DoD) contractors, focuses on protecting Controlled Unclassified Information (CUI). CUI includes both PII & PHI. However, CMMC emphasizes securing systems that may incidentally store or process FCI during the course of fulfilling government contracts.
  • FTC Safeguards Rule: This rule, enforced by the Federal Trade Commission (FTC), mandates financial institutions to safeguard customer information. This includes PII like names, addresses, and Social Security numbers used for financial transactions. The Safeguards Rule outlines specific security measures to protect this sensitive data.
  • HIPAA: As mentioned earlier, HIPAA governs the protection of PHI. It applies to healthcare providers, health plans, and healthcare clearinghouses. HIPAA mandates robust security and privacy controls to safeguard PHI and requires covered entities to obtain patient authorization for using or disclosing this information.


Understanding the Overlap

There can be some overlap between PII and PHI. For instance, a healthcare provider may need to collect your name and address (PII) to schedule an appointment. However, once this information is linked to your medical history, it becomes PHI subject to HIPAA regulations.

Kyber Security: Your Partner in Data Protection

Navigating the nuances of PII, PHI, and compliance frameworks can be difficult if you haven’t had much experience with it in the past. We offer a variety of services tailored to businesses with secure data handling practices:

  • Data classification and inventory: We can help identify and classify the data you store and process, ensuring you understand what constitutes PII and PHI.
  • Compliance assessments: Our team can assess your current security posture and identify areas for improvement to meet the requirements of relevant compliance frameworks, like CMMC, FTC Safeguards Rule, and HIPAA.
  • Implementation of data security measures: We offer expertise in implementing robust security controls to protect PII and PHI, encompassing access controls, encryption, and employee training.
  • Ongoing monitoring and support: We provide ongoing monitoring to detect and address evolving threats, ensuring your data remains secure and compliance is maintained.

Remember, data privacy is an ongoing process. Staying informed about the nuances of PII, PHI, and compliance frameworks allows you to make informed decisions and build a secure foundation for your organization.