| POLICY AND PROCEDURES RELATED TO THE PERSONAL HEALTH INFORMATON PROTECTION ACT, 2004
Policy: It is the policy of MHSN, HPC to act in full compliance with the Act. It is understood that as a Community Mental Health Program, funded by the Ministry of Health and Long Term Care, the Agency is defined as a Health Information Custodian.
Procedures:
- Information will be gathered from Program Participants for the following purposes:
- personal information will be gathered to the extent needed to provide the desired level of services to the Participant - statistical information will be gathered to assist with program planning and evaluation - statistical information will also be gathered as required by the Ministry of Health.
- Information will be gathered according to a set format at the outset of an individual’s participation in the Program, and as necessary throughout the time the individual continues to participate in the Program. Participants will be assigned a unique numeric identifier to help protect their identity.
- Only information needed to fulfil the purposes identified to a Program Participant will be collected, used and disclosed. The Agency will take reasonable steps to ensure that the information is as accurate and up-to-date as needed to fulfil the purposes for which it uses the information.
- No files containing personal information belonging to Program Participants will be kept by the Agency. However, the Agency maintains a record of the assigned unique identifiers, and maintains records of the statistical information it gathers.
- Program Participants will keep their own personal files in a secure setting where they receive services. Access will be granted to Program Staff with a signed Form 14 under The Mental Health Act, for use in emergency situations.
- Board Members, Staff and Volunteers will sign and be governed by Confidentiality Agreements, which require them to protect the confidentiality of the information they receive from Participants and to respect the privacy rights of Participants.
- No information about a Program Participant will be disclosed without the express written permission of the Program Participant through an executed Form 14 under The Mental Health Act, or unless otherwise required or permitted by law.
- Information will be retained by the Agency during the time the Participant is in the Program, and will be retained after that time for the period of time required by law. Statistical information is retained indefinitely. When information is disposed, steps are taken to ensure that confidentiality and security are maintained throughout the disposal process.
- The Executive Director shall be designated as the Contact Person for the Network for the purpose of:
1. Providing information regarding Agency information practices to the Public. 2. Handling requests for information – either internal or external. 3. Receiving complaints about contraventions of PHIPA or its regulations. 4. Ensuring security of information 5. Notifying Program Participants of issues 6. Limiting collection, use and disclosure of information.
- Questions about this policy or about the information practices of the Agency may
be addressed to the Privacy Officer, Mental Health Support Network HPE Corp, C-2, 350 Front Street, Belleville, ON K8N 5M5.
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