Data Use Agreements

Updated 2026-05-17

Individually Identifiable Information (III) refers to any information that can be used to distinguish or trace an individual's identity, either directly or indirectly.

Context in VA Operations

Within the Department of Veterans Affairs (VA) (VA), particularly the Department of Veterans Affairs (VA) (VHA), III is subject to stringent privacy and security protocols. The handling, access, use, and disclosure of III are governed by Data Use Agreements (DUAs) and various VA directives to comply with federal laws and protect veteran privacy.

III often overlaps with Protected Health Information (PHI) when it pertains to an individual's health status or healthcare services.

Data Use Agreements (DUAs)

Data Use Agreements (DUAs) are formal agreements mandated by the VHA to govern the access, use, and disclosure of sensitive veteran information, including III.

Purpose and Scope of DUAs

DUAs are designed to ensure that III and PHI are handled in strict accordance with federal laws, regulations, and VA policies. Key aspects include:

• Compliance: Ensuring adherence to privacy regulations such as HIPAA and other federal statutes governing health information.
• Access Control: Defining who can access specific data, for what purposes, and under what conditions.
• Disclosure Guidelines: Setting rules for how III and PHI can be disclosed to third parties, including business associates and subcontractors working on behalf of the VHA.
• Data Security: Requiring parties to implement appropriate safeguards to protect the confidentiality, integrity, and availability of the data.

VHA Directive 1080.01 provides specific guidance on the requirements and implementation of DUAs. These agreements are crucial for maintaining the privacy and security of veteran data within the VA ecosystem.

Master Person Index (MPI)

The Master Person Index (MPI), formerly known as the Master Veteran Index (MVI), is an enterprise system used by the VA for health care identity management. It plays a critical role in managing and securing veteran information, including III.

Purpose and Function of MPI

The MPI serves to:

• Establish Relationships: Create and maintain relationships between various departmental entities within the VA's healthcare system.
• Identity Management: Provide a centralized and authoritative source for identifying and linking veteran health records across different VA systems.
• Data Governance: Support the VA's overall data governance framework, particularly within the VHA, by ensuring consistent and accurate identification of individuals.

The MPI is a critical component of the VA's efforts to manage and secure veteran information effectively, ensuring that III is correctly associated with the right individual across all systems.