Chatham-Kent Family Health Team’s (FHT) mission is to provide multidisciplinary care with integrity, compassion and excellence for our neighbours, family and community.
As part of our mission, we are committed to promoting patient privacy and protecting the confidentiality of the health information we hold. To this end, the Chatham-Kent Family Health Team has developed a comprehensive policy which outlines the standards to which the Chatham-Kent Family Health will attain in protecting the confidentiality of our patient’s personal health information.
Chatham-Kent FHT is the Health Information Custodian under the Personal Health Information Protection Act, 2004. Our doctors are part of the Chatham-Kent Family Health Organization that partners in providing services to Chatham-Kent FHT patients. For the purposes of privacy obligations, our doctors and all FHT staff are agents of Chatham-Kent FHT and abide by this policy. If a doctor leaves the Family Health Organization and the FHT, his/her patients will be notified and will have a choice whether to transfer their health records in accordance with College rules.
Principle 1 – Accountability for Personal Health Information
Chatham-Kent FHT demonstrates our commitment to privacy by implementing privacy policies and procedures to protect the personal health information we hold and by educating our staff and any others who collect, use or disclose personal health information on our behalf about their privacy responsibilities.
Principle 2 – Identifying Purposes for Collecting Personal Health Information
At or before the time personal health information is collected, Chatham-Kent FHT will identify the purposes for which the information is collected. Generally speaking, Chatham-Kent FHT collects personal health information for purposes related to direct patient care, administration and management of our programs and services, patient billing, administration and management of the health care system, research, teaching, statistical reporting, fundraising, meeting legal obligations and as otherwise permitted or required by law.
A patient who presents for treatment gives implied consent for the use of his or her personal health information for authorized purposes, unless expressly instructing otherwise.
When personal health information that has been collected by Chatham-Kent FHT is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is permitted or required by law, consent will be required before the information can be used for that purpose.
Principle 3 – Consent for the Collection, Use and Disclosure of Personal Health Information
Generally speaking, Chatham-Kent FHT requires consent in order to collect, use, or disclose personal health information. However, there are some cases where Chatham-Kent FHT may collect, use or disclose person health information without consent as permitted or required by law. For example, Chatham-Kent FHT does not require consent for using or disclosing information for billing, risk management or quality improvement purposes. Also legal, medical, or security reasons may make it impossible or impractical to seek consent.
Chatham-Kent FHT can assume that an individual’s request for treatment constitutes implied consent for specific purposes, unless expressly instructed otherwise.
If consent is sought, an individual may choose not to give consent. If consent is given, an individual may withdraw consent at any time, but the withdrawal cannot be retrospective. The withdrawal may also be subject to legal or contractual restrictions and reasonable notice.
Principle 4 – Limiting Collection of Personal Health Information
Chatham-Kent FHT limits the amount and type of personal health information we collect to that which is necessary to fulfill the purposes identified. Information is collected directly from the individual, unless the law permits or requires collection from third parties.
Principle 5 – Limiting Use, Disclosure and Retention of Personal Health Information
Personal health information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law. Personal health information will be retained only as long as necessary for the fulfillment of those purposes. Personal health information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made anonymous.
Principle 6 – Accuracy of Personal Health Information
Chatham-Kent FHT will take reasonable steps to ensure that information is as accurate, complete, and up to date as is necessary to minimize the possibility that inappropriate information may be used to make a decision about the individual.
Principle 7 – Safeguards for Personal Health Information
Chatham-Kent FHT has put in place safeguards for the personal health information we hold, which include:
- Physical safeguards (such as locked filing cabinets);
- Organizational safeguards (such as permitting access to staff on a “need-to-know” basis only); and
- Technological safeguards (such as the use of passwords, encryption, and audits).
Chatham-Kent FHT requires anyone who collects, uses or discloses personal health information on our behalf to be aware of the importance of maintaining the confidentiality of personal health information. This is done through the signing of confidentiality agreements, privacy training, and contractual means.
Chatham-Kent FHT takes steps to ensure that the personal health information we hold is protected against theft, loss and unauthorized use or disclosure.
Care is used in the disposal or destruction of personal health information, to prevent unauthorized parties from gaining access to the information.
Principle 8 – Openness about Personal Health Information
Information about Chatham-Kent FHT’s policies and practices relating to the management of personal health information are available to the public, including:
- Contact information for our primary privacy contacts, to whom complaints or inquiries can be made;
- The process for obtaining access to personal health information we hold, and making requests for its correction;
- A description of the type of personal health information we hold, including a general account of our uses and disclosures; and
- A description of how an individual may make a complaint to Chatham-Kent FHT or to the Information and Privacy Commissioner of Ontario.
Principle 9 – Individual Access to Personal Health Information
Individuals may make written requests to have access to their records of personal health information, in accordance with Chatham-Kent FHT’s policy for access and correction to records.
Chatham-Kent FHT will respond to an individual’s request within reasonable timelines and costs to the individual, as governed by legislation. Chatham-Kent FHT will take reasonable steps to ensure that the requested information is made available in a form that is understandable.
Individuals who successfully demonstrate the inaccuracy or incompleteness of their personal health information may request that we amend their information. In some cases instead of making a correction, individuals may ask to append a statement of disagreement to their file.
Please Note: In certain situations, Chatham-Kent FHT may not be able to provide access to all the personal health information we hold about an individual. Exceptions to the right of access requirement will be in accordance with law. Examples may include information that could reasonably be expected to result in a risk of serious harm or the information is subject to legal privilege.
Principle 10 – Challenging Compliance with Chatham-Kent FHT Privacy Policies and Practices
An individual may ask questions or challenge our compliance with this policy or with the Personal Health Information Protection Act, 2004 by contacting the Executive Director.
Chatham-Kent Family Health Team
Suite 111, 20 Emma Street,
Chatham, N7L 5K5
Chatham-Kent FHT will receive and respond to complaints or inquiries about our policies and practices relating to the handling of personal health information. We will inform individuals who make inquiries or lodge complaints of other available complaint procedures. Chatham-Kent FHT will investigate all complaints. If a complaint is found to be justified, Chatham-Kent FHT will take appropriate measures to respond.