|Area Responsible for Administration:||Privacy Office|
|Approval Authorities:||Senior Executive Committee|
|Revision History:||December 2017|
|Review Timeline:||Every three years or when significant changes occur.|
To appropriately collect, use and share personal health information held by Seneca in accordance with the Personal Health Information Protection Act (PHIPA) and all other applicable privacy legislations.
This policy applies to personal health information in Seneca’s custody or control subject to PHIPA.
Information about an identifiable individual, including:
Note: Information about an individual acting in a business or professional capacity is not personal information. This includes the individual’s name, title, work address (including office location), work telephone number and business email address.
Personal health information
Includes any identifying information about an individual’s health or health history, health care, payments or eligibility for health care, eligibility for health care coverage and Ontario health card number.
Health information custodian
Health information custodians under PHIPA are described as:
An individual authorized by a health information custodian to do anything on behalf of the custodian with respect to personal health information.
To gather, acquire, receive or obtain personal health information by any means from any source.
To view, handle or otherwise deal with personal health information. This does not include the disclosure of personal health information.
Note: The sharing of information between custodian and agent is considered a use and not a disclosure or a collection.
To make personal health information available or to release it to another health information custodian or person.
The collection, use or disclosure of an individual’s personal health information by a health information custodian that has been clearly and unmistakably approved by that individual. Express consent must be explicitly provided, either verbally or in writing.
The collection, use or disclosure of an individual’s personal health information that a health information custodian concludes was approved by that individual.
Any observation, examination, assessment, care, service or procedure that is completed for a health-related purpose and is carried out or provided to diagnose, treat or maintain an individual’s physical or mental condition; to prevent disease or injury or to promote health; or as part of palliative care.
Circle of care
Term used to describe the conditions that allow health information custodians to rely on assumed implied consent when collecting, using or disclosing individuals’ personal health information for the purpose of providing care.
Circle of care may include doctors, nurses, pharmacists, physiotherapists, clinical clerks and employees assigned to one’s health care. Not included are health care information custodians who are not part of one’s direct or follow-up treatment.