Privacy Of Personal Health Information Policy Page 2

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Express Consent
Explicit, informed and voluntary consent of clients/SDMs is required if the purpose for collection, use and
disclosure is not described in the notice statement or if the collection, use and disclosure of personal health
information is for purposes other than for the provision of health care.
Exception to Consent for Collection, Use and Disclosure
(Reference: Personal Health Information Protection Act)
In certain circumstances personal health information can be collected, used or disclosed without the
knowledge and consent of the individual. For example:
In compliance with a court order, through the execution of a search warrant;
In compliance with a duly authorized request from the coroner's office;
When fulfilling an obligation to Report a health professional who has sexually abused a client;
When fulfilling an obligation to inform a potential victim of violence of a client’s intention to
inflict harm;
When fulfilling a legal obligation to report suspected child abuse;
When fulfilling an obligation to inform an appropriate family member, health care professional
or police, if necessary, of a client’s intention to end his/her life;
When following the advice of legal counsel acting on behalf of Gerard Philipps-Gange.
Disclosure to Third Parties
If the third party to which patient data are disclosed is not a recognized health information custodian (i.e., a
health professional, a healthcare organization, OHIP, CIHI), then before patient data are disclosed, the third
party must sign an agreement with Gerard Philipps-Gange to hold the patient data in confidence, and use it
only for the agreed upon purpose.
LIMITING COLLECTION
When practical, patient data are to be collected directly from the patient/SDM. If necessary with the consent
of the patient/SDM, data can be collected from secondary sources such as relatives or friends, as appropriate.
LIMITING USE. DISCLOSURE AND RETENTION
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 required by law. Gerard Philipps-Gange is
responsible for ensuring that records are stored safely and confidentially for no longer than the period of time
necessary to satisfy the identified purposes of the records and to meet legal requirements.
Preservation of Records
As a health information custodian, Gerard Philipps-Gange must ensure that, during the retention period of
records, client data remains usable and unaltered, despite aging record media. This may require storing
records in a controlled environment and may require transferring records to fresh and/or different media
from time to time. Such transfers will be done only after confidentiality is assured.
SAFEGUARDS FOR PERSONAL HEALTH INFORMATION
Authorized Users
Client data will be used only in a manner consistent with the identified purposes and will be used only by
those persons who are fulfilling those purposes.
Access Controls
Access to client data (whether in written, verbal or digital form) is to be strictly controlled.
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