Area Responsible for Administration: Privacy Office
Approval Authorities: Senior Executive Committee
Approval Date: None
Revision History: December 2017
Review Timeline: Every three years or when significant changes occur.

Purpose

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.

Scope

This policy applies to personal health information in Seneca’s custody or control subject to PHIPA.

Key Definitions

Personal information

Information about an identifiable individual, including:

  • Race, national or ethnic origin, religion, age, sex, sexual orientation and marital or family status
  • Employment and educational history
  • Medical, psychiatric and psychological history, prognosis, condition, treatment and evaluation
  • Any identifying number (e.g. Social Insurance Number, student number, symbol or other particular assigned to the individual)
  • Home address and telephone number
  • Personal opinions of, or about, the individual
  • Name, where it appears with, or reveals, the individual’s personal information
  • Correspondence sent to Seneca by the individual that is implicitly or explicitly of a private or confidential nature and any reply to that correspondence that would reveal its contents.

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:

  • Health care practitioners or a group of practice of health care practitioners
  • Persons or organizations providing a community service under the Long-Term Care Act, 1994
  • A community care access centre
  • Public or private hospitals
  • Psychiatric facility under the Mental Health Act, 1990
  • An institution under the Mental Hospitals Act, 1990
  • An independent health facility under the Independent Health Facilities Act, 1990
  • A long-term care facility under the Nursing Homes Act, 1990; Charitable Institutions Act, 1990; or Homes for the Aged and Rest Homes Act, 1990
  • A ‘care home’ within the meaning of the Tenant Protection Act, 1997, which may be, for example, a retirement home
  • A pharmacy
  • A laboratory or a specimen collection centre under the Laboratory and Specimen Collection Centre Licensing Act, 1990
  • An evaluator under the Health Care Consent Act, 1996 or an assessor under the Substitute Decisions Act, 1992
  • A board of health together with its medical officer of health under the Health Protection and Promotion Act, 1990
  • The ministry of Health and Long-Term Care
  • Any other person prescribed by the regulations as a health information custodian.
Agent
An individual authorized by a health information custodian to do anything on behalf of the custodian with respect to personal health information.
Collection
To gather, acquire, receive or obtain personal health information by any means from any source.
Use

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.

Disclosure
To make personal health information available or to release it to another health information custodian or person.
Express consent
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.
Implied consent
The collection, use or disclosure of an individual’s personal health information that a health information custodian concludes was approved by that individual.
Health care
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.

Policy

  1. Policy Statement

    Seneca is committed to protecting students’ privacy and ensuring the confidentiality of their personal health information. The types of personal health information Seneca collects may include name, date of birth, health history, Ontario health card number and records of care provided. Seneca collects, uses and discloses personal health information for the following purposes:
    • To provide assessment, counselling, treatment, referral and/or consultation services as requested by patients
    • To obtain payment for services or goods provided. Payment may be obtained from the individual, Ontario Health Insurance Plan, Workplace Safety and Insurance Board, private insurers or others
    • To conduct quality improvement and risk management activities as required by regulations
    • To promote the Seneca Health Centre, Counselling and Accessibility Services, new services, special events and opportunities (seminar or conference). Seneca will obtain express consent from patients prior to collecting or handling personal health information for these purposes
    • To comply with external regulators. Health Care professionals at Seneca are regulated by the College of Physicians and Surgeons Ontario, College of Psychologists of Ontario, College of Social Workers and Social Service Workers, College of Occupational Therapists Association, College of Nurses of Ontario and other licensing bodies that may inspect our records and interview professional staff as part of their regulatory activities in the public interest
    • For other purposes permitted by law.
    Seneca will collect, use and disclose only as much personal health information as is needed to achieve these purposes. Students can withhold or withdraw consent to the collection, use or disclosure of personal health information by contacting Seneca.
  2. Access to Health Records

    Individuals have the right to seek access to their health records kept at Seneca or to request a correction to a record that is inaccurate or incomplete, subject to PHIPA.
  3. Questions and/or Concerns

    Individuals may contact the Privacy Office about Seneca’s privacy practices:

    Privacy Office
    Seneca
    8 The Seneca Way
    Markham, Ontario
    L3R 5Y1

    Email: privacyoffice@senecacollege.ca  
    Telephone: 416.491.5050 ext. 77846

    Individuals may contact the Seneca Health Centre or Counselling and Accessibility Services directly about their health records.

    Counselling and Accessibility Services
    Seneca
    1750 Finch Avenue East
    North York, Ontario
    M2J 2X5

    Email: senecacnas@senecacollege.ca
    Telephone: 416.491.5050 ext. 22900

    Seneca Health Centre
    Seneca
    1750 Finch Avenue East
    North York, Ontario
    M2J 2X5

    Email: health.centre@senecacollege.ca
    Telephone: 416.491.5050 ext. 22965

    Individuals have the right to contact the Information and Privacy Commissioner of Ontario about Seneca’s privacy practices or how their personal health information has been handled.

    Information and Privacy Commissioner of Ontario
    2 Bloor Street East, Suite 1400
    Toronto, Ontario
    M4W 1A8

    Email: info@ipc.on.ca
    Telephone: 416.326.3333

Supporting Documentation

Related Seneca Policies

Related Materials

  • None