De-identification is not anonymity

The move: specify the privacy method instead of waving at privacy intent. Safe Harbor Useful when the project can remove the listed identifiers and still keep enough signal. It is straightforward, but it can destroy dates, geography, and rare-event context that some AI work depends on. Expert Determination Useful when the project needs richer data. The tradeoff is that a qualified expert must assess re-identification risk and document why it is very small under the planned controls. AI-specific risk Free text, longitudinal patterns, device metadata, and rare combinations can carry identity even without names. Treat de-identification as one layer with…

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