Could an entity with sufficient resources just FOIA the data? It does not appear to fall into any of the FOIA exemptions or exclusions. The closest would be #6,

Could an entity with sufficient resources just FOIA the data? It does not appear to fall into any of the FOIA exemptions or exclusions. The closest would be #6, which protects information that would constitute a clearly unwarranted invasion of personal privacy. But since researchers are accessing this data, shouldn't it already be very carefully anonymized? https://www.hhs.gov/foia/exemptions-and-exclusions/index.html https://www.hhs.gov/foia/exemptions-and-exclusions/index.htm...