I'm not a lawyer but "codice fiscale" is not PHI. The Italian Data Protection Authority puts codice fiscale under PII[0] and it's not mentioned in the PHI section[1,2,3,4].
First off, good work! It is always nice to help people deal on this (sicked and badthought) platforms.
Anyhow, you should check also if a "tessera sanitaria" is considered a PHI since it includes the "codice fiscale" (and if I recall correctly, it is used often in "fascicoli sanitari" to identify an individual).
Anyhow, you should check also if a "tessera sanitaria" is considered a PHI since it includes the "codice fiscale" (and if I recall correctly, it is used often in "fascicoli sanitari" to identify an individual).
But well, I'm not a lawyer either.