Canadian Shield Health Care Services recognizes the importance of respecting and protecting the private information of all individuals associated with the organization. Canadian Shield Health Care Services is committed to protecting Personal Information (PI) and Personal Health information (PHI) by educating and providing on-going training, monitoring, maintaining safeguards and conducting regular audits.
Canadian Shield Health Care Services’ Privacy Protection Strategy is governed by the information handling practices of the Personal Information Protection and Electronic Documents Act (PIPEDA), Personal Health Information Protection Act (PHIPA), and all federal, provincial and professional standards.
Canadian Shield Health Care Services will take every effort necessary to respect the right to privacy of its clients, employees, stakeholders, and proprietary information.
All Canadian Shield Health Care Services employees are responsible to ensuring that personal information and personal health information is held in the strictest confidence. Our Privacy Officer is responsible for the overall compliance of all legal requirements and privacy practices.
All employees of Canadian Shield Health Care Services are to maintain the confidentiality of information they are privy to in the course of their employment. This policy continues even after the employment relationship between Canadian Shield Health Care Services and the employee has ended. All employees are required to sign a Confidentiality Agreement upon hiring and review annually.
COLLECTION OF PRIVATE INFORMATION
Personal information and personal health information is collected in accordance with PHIPA, PIPEDA and other applicable legislation.
For clients, Canadian Shield Health Care Services will only collect, use, access, disclose and store the minimum amount of information required to provide safe and competent care.
For employees, Canadian Shield Health Care Services will only collect, use, access, disclose and store the minimum amount of information required to facilitate the administration of the employee-employer relationship.
Consent of the Client or Employee is required for the collection, use, or disclosure of personal information and personal health information. Consent shall be obtained either verbally, in writing, or by completing and signing an applicable Consent Form. A consent may be withdrawn at any time, subject to reasonable notice and legal restrictions.
A client consent is considered valid through to the end of services, provided the reasons for the consent have not changed.
For individuals who are unable to provide consent due to serious illness, mentally handicapped, dementia or is a minor, consent will be obtained by a legal guardian, authorized authority, power of attorney or executor.
Personal Health Information may be collected, used, or disclosed without knowledge and/or consent of the patient in circumstances where legal, medical, or security reasons make it impossible or unreasonable to seek patient consent.
If at any time we require more or different information, or your information is required for a purpose other than originally provided or discussed, a new consent will be required.
Canadian Shield Health Care Services will seek your consent to disclose personal information outside of your Circle of Care when appropriate access requests are received. All third-party information disclosures are documented.
The Mental Health and Wellness division complies with the Limits of Confidentiality as per legislation. The Limits of Confidentiality are reviewed with Client at every contact.
STORAGE OF PRIVATE INFORMATION
Storage of private information, physicals and digital, is done in accordance with the Personal Information Protection and Electronic Documents Act, 2000, Personal Health Information Protection Act, 2004.
Security safeguards are implemented in accordance with PHIPA and PIPEDA to protect personal information and personal health information against unauthorized access, disclosure, or copying, as well as loss and/or theft. All employees must be aware of the importance of maintaining confidentiality of Personal Health Information. All Canadian Shield Health Care Services employees are oriented and trained on privacy practices at the time of hire and sign a confidentiality agreement.
The nature of the safeguard will vary depending on the sensitivity of the information collected and the format of that information. Methods of protection include:
a) Physical Safeguards: All physical information is securely stored in monitored areas in accordance with the Personal Information Protection and Electronic Documents Act, 2000 and the Personal Health Information Protection Act, 2004.
b) Administrative Safeguards: Canadian Shield Health Care Services regularly reviews and updates policies, procedures, and training to limited access to only authorized personnel. We follow a robust system of access controls and regularly maintain authorizations on a need-to-know basis. We ensure employees and other agents are aware of their ongoing obligation to avoid collecting, using, or disclosing more personal health information than is necessary.
c) Technical Safeguards: Secure computer networks, regular software updates, strong passwords, secure email, email confidentiality statements, encryption, firewalls & virus protection, are managed by a third-party IT provider to ensures Canadian Shield Health Care Services cyber security practices are always evolving with privacy requirements.
d) Education: Canadian Shield Health Care Services ensure their employees and other agents are trained at hiring through Orientation and participate in ongoing privacy education and awareness. All employees participate in privacy and confidentiality refresher training annually.
e) Audits: Canadian Shield Health Care Services maintains, monitors, reviews and archives audits. We conduct an annual Privacy Impact Assessment (PIA) to identify and manage privacy and information security risks associated with providing physical, mental, and virtual health care services.
USAGE OF PRIVATE INFORMATION
For our clients, Canadian Shield Health Care Services will only collect, use, access, disclose and store the minimum amount of personal information and personal health information required to provide safe and competent care.
For our employees, Canadian Shield Health Care Services will only collect, use, access, disclose and store the minimum amount of personal information required to facilitate the administration of employee-employer relationship.
ACCESS TO YOUR PERSONAL INFORMATION
For clients, your personal information and personal health information is only accessible with individuals involved in your care. For employees, your personal information is only accessible by Human Resources or management individuals who have direct involvement in facilitating the administration of the employee-employer relationship.
In rare cases, Canadian Shield Health Care Services may be required by law or other lawful authority to release personal information, such as a court order or subpoena.
REQUEST FOR YOUR PERSONAL INFORMATION
Third Party Requests, written queries, including those by lawyers, police officers or other agencies, regarding employee and/or Client information must be directed to the Management Team
Requests for information concerning employees and/or Clients must be made in writing, outlining the information required, and must be accompanied by the employee’s/client’s written and signed consent to release such information.
Home and Community Care/LHIN/Ontario Health must be notified of any request for information relating to referred clients.
Canadian Shield Health Care Services shall allow individual access to their personal health information in accordance with PHIPA. An individual has the right to challenge the accuracy and completeness of their personal health information and have it amended, as appropriate.
An employee who wishes to view their employment file must put the request in writing to the Management Team. Employees may provide a written notice of correction if any information in the file is viewed as being incorrect. Employees who wish to release information to a third party must provide written permission to do so including specific details of the information to be disclosed. Copies of the requests, finalized covering letter, release of information consent and document(s) are placed in the employee’s personnel file along with a written note from the immediate supervisor.
Limitations can arise in certain circumstances where Canadian Shield Health Care Services may not be able to provide access to all personal health information about an individual. The reasons for denying access must be provided to the requesting individual and all exceptions to the access must be in accordance with applicable legislation. Exceptions may include information that cannot be disclosed due to legal or security reasons or information that is prohibitively costly to provide.
QUESTIONS OR CONCERNS
Any questions, concerns or complaints relating to Canadian Shield Health Care Services information handling practices should be directed to our main office at 705-618-7233. If your questions, concerns or complaints cannot be addressed to your satisfaction, or you wish further information, you can contact our Privacy Officer directly by email at [email protected].
While Canadian Shield Health Care Services appreciates the opportunity to address your questions, concerns, or complaints, you are entitled to contact your provincial Privacy Commissioner’s office if warranted.