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Also not an expert, but I agree. The violation is only if there is PHI - personal health information released. Stating that John Doe was present at X Clinic is a problem; stating that he exists is not.

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Having a record implies that you were present at X Clinic. If it's a specialist clinic, then confirming the existence of patient record could allow someone to infer the condition or a range of conditions. Most clinics won't confirm or deny that a patient is there (or has records) without a release. In this case, though, we don't know where the record was stored.

Good point. My training said no full names, but that was because we were directly associated with a specific product/analysis, so any full names would associate the patient with a particular health... thing.

A name by itself, you are quite right, is not PHI. Thanks for the reminder!

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