Data Transfer or Use Agreements (DTAs/DUAs) are used for the transfer of data related to human trials or patients. The data can be used for research, public health or health care operations.

Data can be sent in a completely de-identified format or as a limited data set, which according to HIPAA Rules includes only the following direct identifiers:

a) Dates of Treatment, admission discharge

b) Birth date, date of death

c) Age (including age 90 or over)

d) Geographic subdivisions such as state, country, town, city, precinct, and zip code

e) Unique codes or identifiers that are not direct identifiers or replicates of a part of direct identifiers

Other Direct Identifiers, as follow, may not be included in a limited data set:

a) Names

b) All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geographic codes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census: (1)The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and (2) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.

c) All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older

d) Telephone numbers, fax numbers

e) Electronic mail addresses

f) Social Security numbers, medical record numbers, health plan beneficiary numbers

g) Account numbers, Certificate/license numbers

h) Vehicle identifiers and serial numbers, including license plate numbers

i) Device identifiers and serial numbers

j) Web Universal Resource Locators (URLs)

k) Internet Protocol (IP) address numbers

l) Biometric identifiers, including finger and voice prints

m) Full face photographic images and any comparable image

n) Any other unique identifying number, characteristic, or code, except as permitted as a means of record identification to allow information de-identified to be re-identified.

Please use our Data Use Agreement template if your transfer falls within these guidelines. If your transfer does not, please contact mta@bcm.edu.