Skip to content

Health-data AI programs: a status brief, not a health-data intake

Health status: Rightmark does not take health data yet (patient records, medical imaging or veterinary records), until a HIPAA program and vendor agreements are in place.

Researching a health-data AI program starts with its de-identification method, documented cohort, data-use agreement, permissions, and access controls. The HIPAA de-identification guidance does not establish that a collection is accepted by Rightmark, that a particular record can be licensed, or that any per-record value exists. This brief provides questions for reading a program's evidence; it does not report a count or survey of programs. The current health route is status and research only. Do not submit patient records, images, clinical notes, veterinary records, or health samples for intake or appraisal. General information, not legal advice.

Updated

On this page

Public evidence map

Public evidence map (table)
Research questionEvidence to readSafe interpretation
How is data de-identified?HIPAA Safe Harbor and Expert Determination guidanceA method and residual-risk review are required; a label alone is not clearance
What labels exist?Dataset documentation, cohort definitions, annotation protocol, missingness notesLabels describe the collection and its limits, not clinical validity
Who may use it?Data-use agreements, institutional approvals, vendor and transfer termsAccess rights can be narrower than ownership or publication rights
How is value structured?A dated public collaboration or licensing recordRecord the structure and source; do not turn it into a per-record rate
What changes over time?Consent withdrawal, deletion, model use, retention, and security updatesThe program needs a maintained governance record

The HIPAA de-identification guidance HHS, (opens in a new tab) describes two de-identification methods and notes that de-identification reduces, but does not eliminate, risk. GDPR Article 9 Official Journal of the European Union, (opens in a new tab) treats health data as a special category of personal data. The US bulk-data rule Federal Register, (opens in a new tab) adds a separate transfer and access question for certain sensitive personal data and covered persons. These sources are reasons to pause and review, not a checklist that makes a collection safe by itself.

General information, not legal advice.

Keep status categories separate

Publicly reported means a source describes a program or transaction. Documented means the program publishes its method, scope, and governance evidence. Eligible for Rightmark intake is a separate product decision and is currently false for health data. Do not collapse these labels into one readiness mark or use a public collaboration to imply consent, de-identification, or approval of a new collection.

Narrower research conclusion

The public record can support a taxonomy of program components. It does not change Rightmark's current decision not to accept health data. A disclosed collaboration structure is evidence of that public arrangement, not a price for another collection. When comparing programs, retain the record ID, source date, permitted use, and limitations. Do not infer an intake path or an offer from a public announcement.

Fictional status worksheet

For a hypothetical university research program, mark each line publicly documented, needs counsel, or not evidenced:

  • collection purpose and permitted AI uses;
  • de-identification method and residual-risk analysis;
  • consent, notice, withdrawal, and deletion route;
  • data-use agreement, institutional approval, and vendor terms;
  • labels, provenance, missingness, and quality controls;
  • transfer, access logging, retention, and breach response;
  • revenue share or access structure, if a dated public record states one.

Do not attach a patient file to this worksheet. A synthetic description is enough for the research exercise.

Sources

  1. HHS: Guidance Regarding Methods for De-identification of Protected Health Information in Accordance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule (opens in a new tab)
  2. Official Journal of the European Union: Regulation (EU) 2016/679 (General Data Protection Regulation), Article 9: Processing of special categories of personal data (opens in a new tab)
  3. Federal Register: Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (opens in a new tab)
  4. Rightmark: Trust
  5. Rightmark: Deal Tracker

Read the Trust page for current status and safeguards.

This page does not accept health data and does not provide a health-data appraisal.