7. DDG Governance

Governance for DDG will be provided by the Data Subcommittee with support from the Risk Management Subcommittee. The Subcommittees are part of the CalHHS governance structure as described in the CalHHS Information Strategic Plan. Governance for the CalHHS DDG will provide the following support for departments and offices.

• Maintain the CalHHS DDG, which will include updates and revisions to the document as well as annual reviews for currency.

• Coordinate integration of the CalHHS DDG into the Statewide Health Information Policy Manual (SHIPM), Section 2.5.0 De-Identification and the CalHHS Open Data Handbook.

• Convene a Peer Review Team (PRT).

• Provide for escalation of issues that cannot be resolved by the PRT.

The CalHHS PRT will include no more than two representatives from each department or office. Membership of the PRT is expected to include individuals with the following background and experience.

• Knowledge of and experience with generally accepted statistical and scientific principles and methods for rendering information not individually identifiable.

• Knowledge of and experience with legal principles associated with data de-identification in compliance with California IPA and HIPAA.

The PRT will have the following responsibilities:

• Provide review and consultation regarding a department’s DDG to ensure it is consistent with the CalHHS DDG. This may be particularly useful if a department incorporates methods for de-identification in the department’s DDG that have not already been documented in the CalHHS DDG.

• Provide for escalation and review of data de-identification questions or issues that a department is not comfortable resolving independently.

• Develop training tools to be used by departments when developing and implementing department-specific DDGs based on the content of the CalHHS DDG.

• Review and approve each department’s DDG procedure and any alternate forms of de-identification before implementation.

• Review and approve individuals designated by departments as Statistical De-Identification Experts and Statistical De-Identification Supervisor Experts. For departments without staff to meet the minimum qualifications of the Statistical De-Identification Supervisor Expert role, the PRT shall review and approve all individuals prior to a department entering into an agreement for the individual to complete the activities of the Statistical De-Identification Supervisor Expert.

The PRT will not review all disclosures or data released by each department but shall be available for consultation and second opinions.