SI-19(4) Removal, Masking, Encryption, Hashing, or Replacement of Direct Identifiers
Control enhancement of SI-19 De-identification
Control
Remove, mask, encrypt, hash, or replace direct identifiers in a dataset.
Discussion
There are many possible processes for removing direct identifiers from a dataset. Columns in a dataset that contain a direct identifier can be removed. In masking, the direct identifier is transformed into a repeating character, such as XXXXXX or 999999. Identifiers can be encrypted or hashed so that the linked records remain linked. In the case of encryption or hashing, algorithms are employed that require the use of a key, including the Advanced Encryption Standard or a Hash-based Message Authentication Code. Implementations may use the same key for all identifiers or use a different key for each identifier. Using a different key for each identifier provides a higher degree of security and privacy. Identifiers can alternatively be replaced with a keyword, including transforming "George Washington" to "PATIENT" or replacing it with a surrogate value, such as transforming "George Washington" to "Abraham Polk."
Related controls
Need SI-19(4) implemented and evidenced?
We assess where you stand against this control, document the gap, and build the remediation plan your auditor and your board will both accept.
Control catalog and framework text on this page is reproduced from official NIST publications — a public-domain work of the U.S. Government (17 U.S.C. §105). Maverc commentary, groupings, and readiness guidance are our own and are not part of any NIST publication.
