designated action designated process of sharing (1) this, along with 'transfer' need to be properly fleshed out. Perhaps the difference is 'ownership.' When you share, you may retain the right to ownership, but when you transfer, you yield this right.... (2) does sharing including publishing PHI? De-anonymizing? (3) what about 'release?' A 'designated action' that designates a process of sharing permissable. Cooper Stansbury, Elizabeth Umberfield, Kathleen Ford, Marcy Harris share: https://www.merriam-webster.com/dictionary/share (1) to partake of, use, experience, occupy, or enjoy with others