PHI in page URLs

When the address of a page names a condition, a service or a provider, a script that sends that address can send health information with it.

[AUTHOR NAME][ROLE], COMPLI3D[DATE]

Not legal advice. This is a plain definition, not a legal test. Whether data is protected health information depends on who holds it and why. Ask your counsel.

PHI in page URLs describes a page address that, on its own or together with other data, could reveal something about a person’s health. For example, example.org/programs/alcohol-detox/verify-insurance names a service. When a tracking script sends that address to an ad network along with an IP address or a cookie, the network learns that a specific browser looked at that service.

Most ad pixels send the full page address with every event. Query strings can add more: a form that puts answers in the URL, such as ?program=detox, sends those answers too.

Page URL
example.org/programs/alcohol-detoxremoved
Referrer
example.org/conditions/opioid-useremoved
Click ID
Cj0KCQ_sample_click_idkept
Event code
c_7f3akept

The fix is usually not renaming every page. It is making sure page details never leave in the first place: hold scripts until the visitor opts in, and report conversions from the server with only a click ID and an opaque code.

Key takeaways

  • A page address can name a condition, a service or a provider.
  • Most ad pixels send the page address with every event.
  • Keep page details out of the request instead of trying to rename every page.
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