ClearDATA Locate® Service Description
Summary
This is the Service Description for all products under the ClearDATA Locate family.
1. ClearDATA Locate® Mask
ClearDATA Locate Mask is a Software-as-a-Service (SaaS) offering that enables healthcare organizations to mask or redact data elements within their datasets. Various laws restrict healthcare organizations’ ability to share fully identifiable health information. Customers can use ClearDATA Locate Mask to choose which data elements to redact for a particular purpose, allowing extraction of full utility from data.
Supported Data Elements
ClearDATA Locate Mask supports masking the following HIPAA identifiers:
| Mask Standard | Mask Premium* |
| Name | Medical Record Number |
| Date | Account Number |
| Telephone Number | Health Plan Beneficial Number |
| Geographic Data | Certificate/License Number |
| Fax Number | Vehicle identifier and serial numbers, including license plates |
| Social Security Number | Device identifiers and serial numbers |
| Email Address | |
| Web URL | |
| IP Address | |
| Age |
*Masking data elements in the Mask Premium tier requires use of more complex machine learning and natural language processing to detect the data and use the appropriate context to determine if the data element is an identifier. Mast Premium services are therefore charged at a higher rate.
Supported File Types
ClearDATA Locate Mask supports both text and images in the following formats:
- TXT
- CSV
- JSON
- PNG
- JPEG
Handwritten text is not supported by ClearDATA Locate Mask.
Data Lifecycle
Customers can upload data through the ClearDATA Portal or use the ClearDATA Locate API to send data to the ClearDATA Locate Mask endpoint. Data submitted via the ClearDATA Portal is stored in an encrypted storage system, processed by the ClearDATA Locate Mask software, and then purged from storage. Data submitted to the API is never stored on a system, and is only processed by the software. All output data generated by ClearDATA Locate Mask is stored on an encrypted and secure storage system and is available for download for 72 hours by the user who submitted it. After 72 hours the output data is deleted and any dataset will need to be resubmitted to receive masked output.
HIPAA De-identification
ClearDATA does not certify that output from ClearDATA Locate Mask is de-identified under the HIPAA standards. That is because ClearDATA Locate Mask does not recognize and mask data elements other than those data elements listed above. For example, it would not mask the label that a patient is the “President of the United States,” which would be identifiable information. The customer thus has the responsibility to determine if the output data contains any remaining identifying data after masking, before the customer uses or shares the data.
2. ClearDATA Locate® Trace
ClearDATA Locate Trace is a healthcare-aware distributed tracing software solution for use in Kubernetes-based environments. It is run as a Kubernetes pod and a specific configuration within a Kubernetes cluster. ClearDATA Locate Trace runs as a sidecar proxy that monitors data requests in the pod where ClearDATA Locate Trace is loaded. Data is sent, via encrypted connection, to a ClearDATA evaluation pipeline. ClearDATA Locate Trace will evaluate the text contained in the request and determine if the data contains the data elements listed above. The request header will then be updated with a tag named locate.detect-phi=true to reflect that the request contained HIPAA identifiers. The requests can be viewed through any Distributed Tracing software, such as Jaeger or Zipkin.
Example
As an example, the application processes medical notes for a healthcare provider. These notes are sent through a microservice-based patient note application. A sample note is below.
Sample Medical Note
Visit Information
OR Date : 12/04/2012 .
Diagnosis : OTHER AND UNSPECIFIED DISEASES OF APPENDIX 543.9 .
Proposed Procedure : Laparoscopy , surgical , appendectomy 44970 Appendectomy 44950 .
Type of Visit : Chart review only .
Last in-person/phone visit : None .
Patient Age : 48 years old .
Past Surgical History
Previous Surgeries : left below the knee amputation .
PONV Risk Factors : female , non-smoker , Total Number of Risk Factors : 2 .
Family Anesthesia History
No Problems .
Social Behaviors
Alcohol Use : denies .
Tobacco use : Denies .
Drug use : Denies .
Medications
Outpatient Medications :
1 . acetaminophen 325 mg oral tablet Dose : 2 tabs PO
2 . docusate ( Doc – Q – Lace 100 mg oral capsule ) Dose : 2 caps PO
3 . traZODone 50 mg oral tablet Dose : 1 tab PO
Allergies
Allergic Reactions ( Selected )
No Known Medication Allergies
Review of Systems
NEURO/PSYCH : Developmental delay .
Depression .
Anxiety .
cerebral palsy .
MUSCULOSKELETAL : Hip joint pain .
Physical Examination
Vital Signs
Height : 64 in / 162.5 cm.
Weight : 158 lbs / 71.8 kg.
BMI : 27.1 .
As you can see there are items in the note that can be considered PHI[1] such as Age (48) and Date (12/04/2012).
ClearDATA Locate will tag this request with locate.detect-phi=true. The resultant data will be saved in JSON format, and will look like
Sample Medical Note
‘phi’:
[
{
‘Id’: 0,
‘BeginOffset’: 25,
‘EndOffset’: 27,
‘Score’: 0.562412679195404,
‘Text’: ‘OR’,
‘Category’: ‘PROTECTED_HEALTH_INFORMATION’,
‘Type’: ‘ADDRESS’,
‘Traits’: [
]
},
{
‘Id’: 1,
‘BeginOffset’: 35,
‘EndOffset’: 45,
‘Score’: 0.999784529209137,
‘Text’: ’12/04/2012′,
‘Category’: ‘PROTECTED_HEALTH_INFORMATION’,
‘Type’: ‘DATE’,
‘Traits’: [
]
},
{
‘Id’: 2,
‘BeginOffset’: 307,
‘EndOffset’: 309,
‘Score’: 0.9997351765632629,
‘Text’: ’48’,
‘Category’: ‘PROTECTED_HEALTH_INFORMATION’,
‘Type’: ‘AGE’,
‘Traits’: [
]
},
{
‘Id’: 3,
‘BeginOffset’: 1325,
‘EndOffset’: 1330,
‘Score’: 0.4220290780067444,
‘Text’: ‘.2019’,
‘Category’: ‘PROTECTED_HEALTH_INFORMATION’,
‘Type’: ‘DATE’,
‘Traits’: [
]
}
3. Support
ClearDATA Software Support for ClearDATA Locate is available 8 am -5 pm Central Time via email at locate.support@cleardata.com. ClearDATA Support can assist with the configuration of the software, and ensuring that ClearDATA Locate is receiving your data. ClearDATA Locate does not include Healthcare Managed Services
Service Credits
If ClearDATA Locate’s API is unavailable for more than 30 consecutive minutes, excluding Maintenance, you are entitled to a credit of 2% of the fee for the affected environment, and an additional 1% for each additional full increment of 30 minutes that the API remains unavailable, up to a maximum of $1000 for the month in which the unavailability occurs. Availability of the ingestion service is defined as the service being available to the public internet, and its ability to receive and ingest data from any location. The availability of the ingestion service does not include any localized transmission issues, such as outbound restrictions or local provider issues. Credits that would be available but for this limitation will not be carried forward to future months or applied to other products or services.
Downtime, outages or other service level failures due to Maintenance are not included in the measure of unavailability or response times. “Maintenance” means: a) AWS maintenance as defined in the AWS SLAs; b) ClearDATA scheduled maintenance that is announced at least 5 business days in advance and that is performed within ClearDATA’s maintenance window, currently midnight to 4:00 a.m. United States Central Time; c) maintenance of your configuration that you request and that we schedule with you in advance (either on a case by case basis, or based on standing instructions), such as hardware or software upgrades; or d) critical unforeseen maintenance needed for the security or performance of your configuration or our network.
Extraordinary Events
You are not entitled to a credit for downtime or outages resulting from force majeure events.
Your Breach of the Agreement
You are not entitled to a credit if you are in breach of your agreement with us (including your payment obligations to us) at the time of the occurrence of the event giving rise to the credit. You are not entitled to a credit if the event giving rise to the credit would not have occurred but for your breach of your agreement.
Measurement of Time Periods
For the purpose of determining whether a credit is due, time periods will be measured from the time stamp generated by our ticket system, or the time an interruption is recorded in our monitoring system, as applicable. Phone support is not available for this service.
Requests
You must request a credit in writing using the locate.support@cleardata.com support address no later than seven days following the occurrence of the event giving rise to the credit. We will contact you within thirty days to approve or reject the claim or to request more information. If the claim is approved, the credit will appear on your monthly invoice following approval.
Credits are Sole and Exclusive Remedy
The credit remedies provided in this SLA are your sole and exclusive remedy for damages arising from ClearDATA violation of a service level for which credit is provided.
4. Business Associate Agreement (BAA)
For all United States HIPAA Covered Entities, all product offerings in the ClearDATA Locate product family are covered under the BAA in place between you and ClearDATA.