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Privacy and Civil Liberties Data Sharing Agreement Program

Questions and answers about privacy and civil liberties at the Defense Health Agency Data Sharing Agreement (DSA) program.

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Privacy Act at DHA | Privacy and Civil Liberties | Submit a Data Sharing Application | Submit a Data Sharing Application
Q1:

Why is a Data Sharing Agreement required?

A:

The DHA requires an approved DSA when requestors ask to use DHA data. The DHA, as a covered entity, uses the DSA process to:

  • Confirm that data will be used as allowed under the regulations
  • Promote privacy responsibility in the MHS
  • Maintain documentation in case of an investigation or audit
  • Share only the minimum data necessary for the purpose
Q2:

Who needs a Data Sharing Agreement?

A:
  • Business Associates who need DHA data to do work on behalf of the government
  • Government personnel who need DHA data for a research project or a survey
  • Researchers who need DHA data for a research project or survey
  • Students and professionals who need DHA data for an academic research project or for a dissertation
Q3:

How is the Data Sharing Agreement request process initiated?

A:

Requestors submit a Data Sharing Agreement Application (DSAA) endorsed by both the Applicant and Sponsor.

Q4:

How long will it take to obtain an approved Data Sharing Agreement?

A:

A DSA may be approved within 10 business days after a DSAA is approved.

Q5:

Who should be listed on the Data Sharing Agreement?

A:

The Applicant, Government Sponsor, and DHA Privacy and Civil Liberties Office (DHA Privacy Office) are listed on the DSA.

Q6:

Does the Data Sharing Agreement Sponsor need to be a member of the MHS?

A:

Yes, the DSA Sponsor needs to be a member of the MHS.

Q7:

How early should a Data Sharing Agreement Renewal Request be submitted?

A:

The DSA Renewal Request should not be submitted until the contract option year (as listed on the Renewal Request) has been granted.

Q8:

What is personally identifiable information, or PII?

A:

Under DoD 5400.11-R, "Department of Defense Privacy Program," May 14,2007, personally identifiable information (PII) is information about an individual that identifies, links, relates, or is unique to, or describes the individual. Examples are: a social security number; age; military rank; civilian grade; marital status; race; salary; home or office phone numbers; and other demographic, biometric, personnel, medical, and financial information.

Q9:

What is protected health information, or PHI?

A:

Under DoD 6025.18-R, "Department of Defense Health Information Privacy Regulation, protected health information (PHI) is a subset of PII. PHI is health information, including demographic information collected from an individual, created or received by a health care provider, health plan, employer, or health care clearinghouse, and relating to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual; and that identifies the individual; or with respect to which there is a reasonable basis to believe the information can be used to identify the individual.

Q10:

What is de-identified information?

A:

HIPAA defines de-identified data as:

  • Data that does not identify an individual
  • Data that has the 18 categories of direct identifiers removed
  • Data that allows no reason to believe it can be used, alone or in combination with other information to identify an individual
Q11:

What is a limited data set?

A:

DoD 6025.18-R defines a limited data set as PHI that excludes 16 of the 18 direct identifiers. A limited data set may still include the following (potentially identifying) information: admission dates, discharge dates, service dates, dates of birth, and, if applicable, age at time of death (including decedents age 90 or over). Also, five-digit zip code or any other geographic subdivision, such as state, county, city, precinct, and their equivalent geocodes (except street address) may also remain as part of a limited data set (LDS).

DHA Address: 7700 Arlington Boulevard | Suite 5101 | Falls Church, VA | 22042-5101

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