What is Personal Health Information?
Personal health information as described by the Personal Health Information Protection Act, 2004 means identifying information about an individual related to the (a) physical or mental health of the individual (including family health history), (b) the provision of health care to the individual (including identifying a person’s health care provider), (c) a plan of service within the meaning of the Home Care and Community Services Act, 1994 for the individual, (d) payments or eligibility for health care, or coverage for health care, (e) relates to the donation by the individual of any body part or bodily substance of the individual or is derived from the testing or examination of any such body part of bodily substance, (f) is the individual’s health number, or (g) identifies an individual’s substitute decision-maker.
Why I Collect Personal Health Information
Any data that is collected or obtained including personal health information is for the main purpose of providing therapy. Information about a client’s health history, including family history, physical condition and function, and social situation is used to assess health needs and advise clients of their options. Another purpose is obtaining a baseline so that when providing ongoing health services, clients needs can be managed accordingly.
Other examples of why I collect personal health information:
To obtain payment for services or goods provided.
To conduct quality improvement and risk management activities. I review client files to ensure that I provide high quality services. External consultants (e.g. auditors, lawyers, practice consultants, voluntary accreditation programs) may conduct audits and quality improvement reviews on our behalf.
To comply with external regulators. I am regulated by CRPO who may inspect my records as a part of its regulatory activities in the public interest. The CRPO has its own strict confidentiality and privacy obligations. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting illegal behaviour to the authorities. In addition, we may be required by law to disclose personal health information to various government agencies (e.g. Ministry of Health, children’s aid societies, Canada Customs and Revenue Agency, Information and Privacy Commissioner, etc.).
Protecting Personal Health Information
Paper documents are securely locked or in a restricted area. Electronic hardware is under supervision, securely locked or in a restricted area. These systems have strong password protection. Electronic documents are protected by strong encryption. Personal health information is only stored on mobile devices if necessary. All personal health information stored on mobile devices is protected by strong encryption. I try to avoid taking personal health information home to work on there. However, when I do so, I transport, use and store the personal health information securely. Paper information is transferred through sealed, addressed envelopes or boxes by reputable companies with strong privacy policies. Electronic information is either anonymized or encrypted before being transmitted. External consultants and agencies with access to personal information must enter into privacy agreements with us.
Retention and Destruction of Personal Information
As per the College of Registered Psychotherapists of Ontario, client records are maintained for at least 10 years from the date of the last interaction with the client, or 10 years after the client’s 18th birthday. I destroy paper files containing personal health information by cross-cut shredding. I destroy electronic information by deleting it in a manner that it cannot be restored. When hardware is discarded, I ensure that the hardware is physically destroyed or the data is erased or overwritten in a manner that the information cannot be recovered.
Who Can View My Records?
With only a few exceptions, you have the right to see what personal information we hold about you, by contacting Laura Spence. I can help you identify what records I might have about you. I will also try to help you understand any information you do not understand. I will need to confirm your identity, if I do not know you, before providing you with this access. I reserve the right to charge $25.00 for the records. I may ask you to put your request in writing. I will respond to your request as soon as possible and generally within 14 days, if at all possible. If I cannot give you access, I will tell you the reason, as best I can, as to why. If you believe there is a mistake in the information, you have the right to ask for it to be corrected.
Questions or Concerns?
Contact our Information Officer Laura Spence via the contact page and she will attempt to answer any questions or concerns you may have. If you wish to make a formal complaint about the privacy practices, you may make it in writing to our Information officer. She will acknowledge receipt of the complaint and ensure that it is promptly investigated and you are provided with a formal decision and reasons in writing. You also have the right to complain to the Information and Privacy Commissioner of Ontario if you have concerns about our privacy practices or how your personal health information has been handled, by contacting: Information and Privacy Commissioner/Ontario 2 Bloor Street East, Suite 1400 Toronto, Ontario M4W 1A8 Telephone: Toronto Area (416/local 905): (416) 326-3333 Long Distance: 1 (800) 387-0073 (within Ontario) TDD/TTY: (416) 325-7539 FAX: (416) 325-9195 www.ipc.on.ca
This policy is made under the Personal Health Information Protection Act, 2004, S.O. 2004, c. 3.