The term Employees shall refer to all employees, volunteers, seconded workers, students, contractors, and agencies or organizations providing services to or acting on behalf of the Huronia Nurse Practitioner-Led Clinic.
The Huronia Nurse Practitioner-Led Clinic is dedicated to quality patient care and improving the health status of our communities. A patient’s right to privacy is balanced with the Huronia Nurse Practitioner-Led Clinic’s obligation to provide effective health care treatment.
The Huronia Nurse Practitioner-Led Clinic is a medical facility that handles sensitive patient information on a regular basis. In accordance with the Privacy Act, the Huronia Nurse Practitioner-Led Clinic requires all Employees to handle sensitive personal patient information in a confidential and appropriate manner. It is understood that any individuals acting on behalf of the Huronia Nurse Practitioner-Led Clinic will become aware of confidential information regarding our patients through the course of their employment. Employees agree that if confidential information is not effectively protected, the operations of the Huronia Nurse Practitioner-Led Clinic may be threatened, and the well-being and privacy of our patients may suffer irreparably.
Personal Health Information (PHI) is “identifying” information about an individual’s health or healthcare history. It includes:
• The individual’s physical or mental health, including family history
• The provision of health care to the individual
• Long-term care services
• The individual’s health card number
• Blood or body part donations
• Payment of eligibility for healthcare
• The identity of a health care provider or a substitute decision maker for the individual.
A health information custodian (HIC) is an individual or organization that, as a result of their power or duties, has custody or control of personal health information.
Examples of health information custodians include
• Health care practitioners (family physicians, nurses, social workers, dietitians, etc.)
• Hospitals, including psychiatric facilities
• Nursing homes, retirement homes, and long-term care facilities
• Community Care Access Centres
• Ambulance services
• Ministry of Health and Long-Term Care
The Huronia Nurse Practitioner-Led Clinic contact person is an agent of the health information custodian and is authorized on behalf of the custodian to,
a) facilitate the custodian’s compliance with this Act
b) ensure that all agents of the custodian are appropriately informed of their duties under this Act;
c) respond to inquiries from the public about the custodian’s information practices;
d) respond to requests of an individual for access to or correction of a record of personal health information about the individual that is in the custody or under the control of the custodian; and
e) receive complaints from the public about the custodian’s alleged contravention of this Act or its regulations. 2004, c. 3, Sched. A, s. 15 (3).
The Executive Director will act as the Privacy Officer and the contact person for the Huronia Nurse Practitioner-Led Clinic Health Information Custodians.
The contact details for the Privacy Officer are as follows,
The Circle of Care is not a defined term under PHIPA. It is a term of reference used to describe health information custodians and their authorized agents who are permitted to rely on an individual’s implied consent when collecting, using, disclosing, or handling personal health information for the purpose of providing direct health care.
At the Huronia Nurse Practitioner-Led Clinic, the circle of care can include:
• Specialist or other health care providers
• Health care professionals selected by the patient (e.g., pharmacist)
• Administrative personnel
Consent – express consent may be given verbally, in writing, or by electronic means.
Implied consent permits a healthcare custodian to infer from the surrounding circumstances that an individual would reasonably agree to the collection, use or disclosure of his/her personal health information.
What are the implications of PHIPA for the Huronia Nurse Practitioner-Led Clinic?
1. Health information may be sent to a specialist and returned to the primary care provider without patient consent. This is considered to be a transfer of information within the circle of care and is consistent with good clinical care
2. The Huronia Nurse Practitioner-Led Clinic must request and receive express consent before providing health information to anyone outside of the circle of care – e.g., insurance companies, and employers.
3. Huronia Nurse Practitioner-Led Clinic staff must not provide patient health information to anyone other than the patient without the express consent of the patient. This includes the provision of information to family members.
4. Staff must use their best efforts to protect patient confidentiality. Records should be protected, computer screens should not be visible to patients or visitors, and conversations should be kept private.
5. Employees must not access patient records unless required for treatment or care purposes. Doing so unnecessarily or without patient consent is cause for disciplinary action, including dismissal.
The Huronia Nurse Practitioner-Led Clinic abides by the Health Information Protection Act (November 2004), comprising both the Personal Health Information Protection Act (2004) (PHIPA) and the Quality-of-Care Information Protection Act (2004) (QCIPA).
The Huronia Nurse Practitioner-Led Clinic is responsible for the personal information and personal health information under its control and will in good faith endeavor to ensure that all personal information will be kept private, confidential, and secure.
Huronia Nurse Practitioner-Led Clinic employees are accountable for maintaining confidentiality and privacy of all information collected, accessed, or disclosed during and after their employment or professional contact.
To review the Huronia Nurse Practitioner-Led Clinic’s full Privacy and Confidentiality Policy or for any inquiries please contact,
Malcolm Morum, Executive Director