PII and PHI are often used interchangeably — but they are not the same.

PII (Personally Identifiable Information) refers to data that can identify an individual.
PHI (Protected Health Information) refers specifically to health-related data that is linked to an identifiable individual.

The distinction matters because different regulations apply depending on the data type and jurisdiction.

What Is PII?

Personally Identifiable Information (PII) includes any data that can directly or indirectly identify a person.

Common PII Examples

• Full name

• Passport number

• National ID number

• Email address

• Phone number

• Bank account details

• IP address (in many jurisdictions)

PII is regulated under multiple frameworks, including:

• GDPR (European Union)

• CCPA (California)

• PIPL (China Personal Information Protection Law)

What Is PHI?

Protected Health Information (PHI) refers to health-related data connected to an identifiable individual.

PHI typically includes:

• Medical records

• Diagnosis information

• Treatment history

• Insurance numbers

• Medical test results

• Prescription details

In the United States, PHI is regulated primarily under HIPAA.

Key Differences Between PII and PHI

How Different Jurisdictions Treat PII and PHI

United States

• PII is broadly defined under state privacy laws.

• PHI is specifically regulated under HIPAA.

• HIPAA applies only to covered entities (healthcare providers, insurers, etc.).

European Union (GDPR)

Under GDPR:

• PII is referred to as “Personal Data.”

• Health data falls under “Special Category Data.”

• Special category data requires stricter handling and explicit legal basis for processing.

China (PIPL)

China’s Personal Information Protection Law (PIPL) introduces:

• “Personal Information” (similar to PII)

• “Sensitive Personal Information”

Sensitive Personal Information includes:

• Medical and health information

• Financial accounts

• Location tracking data

• Biometric identifiers

Under PIPL:

• Processing sensitive personal information requires specific purpose and strict necessity.

• Cross-border data transfer is subject to security assessment and compliance review.

This makes proper identification and redaction especially critical for cross-border document sharing and multinational transactions.

When Does PII Become PHI?

Health-related information becomes PHI when:

1. It relates to an individual’s physical or mental health condition

2. It is linked to identifiable information

3. It is handled by a covered entity (under HIPAA context)

For example:

• A name alone = PII

• A diagnosis alone (without identifier) = not PHI

• A diagnosis linked to a name = PHI

Why the Distinction Matters in Practice

Misclassifying PHI as generic PII can lead to:

• Regulatory violations

• Audit failures

• Data breach liability

• Cross-border compliance exposure

This is especially relevant in:

• Healthcare data rooms

• M&A due diligence involving hospitals or biotech firms

• Insurance claims documentation

• International data transfers involving Chinese entities under PIPL

Common Misclassification Scenarios

Scenario 1: Financial Report Containing Medical Claims

Insurance payout details tied to a named individual may qualify as PHI.

Scenario 2: Healthcare Contract Shared in Data Room

If patient identifiers are embedded in annexes, the document may contain both PII and PHI.

Scenario 3: Cross-Border Transaction

Documents containing medical data transferred outside China may trigger PIPL security requirements.

Redaction Considerations for PII and PHI

Proper handling requires:

• Identification of direct and indirect identifiers

• Removal of hidden metadata

• Permanent redaction (not visual masking)

• Audit trails for compliance review

• Industry-specific classification logic

AI-driven redaction systems can help detect:

• Personal identifiers

• Health-related terms

• Structured ID numbers

• Sensitive contextual references

This becomes particularly important in regulated environments such as healthcare M&A and secure virtual data rooms.

Frequently Asked Questions

Is PHI a subset of PII?

Yes. PHI includes identifiable health information, which is a subset of personal data.

Does GDPR distinguish between PII and PHI?

GDPR refers to “personal data” and “special category data.” Health data falls under the special category.

How does China PIPL treat health information?

Under PIPL, health data is classified as “Sensitive Personal Information” and subject to stricter protection.

Is anonymized medical data still PHI?

If it cannot reasonably identify an individual, it may not be considered PHI.

Final Thoughts

PII and PHI overlap — but they are regulated differently depending on context and jurisdiction.

Organizations operating across legal, financial, and healthcare sectors must understand:

• Data classification differences

• Regulatory frameworks (GDPR, HIPAA, PIPL)

• Cross-border data handling risks

• The importance of accurate identification before document sharing

For a deeper look at how AI-powered redaction supports secure handling of sensitive data in regulated environments, explore:

👉 https://www.bestcoffer.com/ai-redaction/