At Laurentian University of Sudbury’s (the “University”) Health and Wellness Services, we are committed to protecting the privacy rights of all members of the University community under our care.
Personal health information will be collected, used, or disclosed in compliance with this Notice, the University’s Procedure for Handling Personal Health Information, and the University’s Policy on Freedom of Information and Protection of Privacy.
Health and Wellness Services employs health care practitioners and is subject to the Personal Health Information Protection Act (PHIPA). PHIPA is Ontario’s health-specific privacy legislation. It governs the manner in which personal health information may be collected, used, and disclosed within the health care system. It also confirms an individual’s right to request access to and correct their personal health information under the custody or control of Health and Wellness Services.
Notice of Collection
Health and Wellness Services collects personal health information of students seeking health care, which is defined in PHIPA as:
Any observation, examination, assessment, care, service or procedure that is done for a health‑related purpose and that,
- is carried out or provided to diagnose, treat or maintain an individual’s physical or mental condition,
- is carried out or provided to prevent disease or injury or to promote health, or
- is carried out or provided as part of palliative care, and includes,
- the compounding, dispensing or selling of a drug, a device, equipment or any other item to an individual, or for the use of an individual, pursuant to a prescription, and […]
- a home and community care service that is funded under section 21 of the Connecting Care Act, 2019.
Personal health information is collected for the purpose of providing health care or assisting in providing health care. Health and Wellness Services only collects the personal health information required for these purposes, for consistent purposes, or those purposes otherwise permitted under PHIPA.
Health and Wellness Services typically collects personal health information directly from the individual receiving health care.
Health and Wellness Services will collect the following information:
- name,
- address,
- date of birth,
- health card number,
- medical history, and
- any other information relevant to the medical issue or concern.
By requesting and using the services of the Health and Wellness Services, individuals are assumed to consent to the collection, use, and disclosure of their personal health information as described in this Notice.
In certain circumstances, Health and Wellness Services may collect personal health information indirectly, as permitted under PHIPA. For example, Health and Wellness Services may assume an individual’s implied consent to collect personal health information from other health care practitioners who are in the individual’s circle of care for the purpose of providing continuous and consistent care. Other examples of when Health and Wellness Services may collect personal health information indirectly include when the individual consents, and when the information is reasonably necessary for providing health care or assisting in providing health care and it is not reasonably possible to collect, directly from the individual, personal health information that can reasonably be relied on as accurate and complete, or personal health information in a timely manner.
Notice of Use and Disclosure
Health and Wellness Centre uses and discloses personal health information for the following purposes:
- Providing or assisting in providing health care or treatment;
- Referring individuals to a specialist or a medical professional outside of Health and Wellness Services;
- Educating our personnel, volunteers, students and other trainees;
- Conducting research with consent, or with appropriate Research Ethics Board approval;
- Obtaining payment for health care or treatment (e.g. through OHIP, WSIB, private insurance or other);
- Improving the quality and efficiency with which we provide health care services;
- Planning, administering and managing Health and Wellness Services’ activities;
- Complying with legal obligations and insurance requirements; and
- As otherwise permitted by PHIPA.
The following Health and Wellness Services personnel may be authorized to access personal health information in the course of performing their duties and functions:
- Practitioners who provide care, such as physicians, nurse practitioners, registered nurses, mental health/addiction counselors, case workers, and psychologists; and
- Administrative staff.
There are health care practitioners outside of the Health and Wellness Services who may request access to records of personal health information. We may assume an individual’s implied consent to disclose personal health information to these health care practitioners if they are actively part of the individual’s circle of care. Individuals may instruct the Health and Wellness Services to exclude certain health care providers from their circle of care.
Health and Wellness Services will not disclose personal health information to health care providers outside of an individual’s circle of care without consent, unless permitted or required by law.
Health and Wellness Services will never disclose personal health information to professors, TAs, or other employees of the University without an individual’s express written consent.
Security safeguards
Health and Wellness Services ensures the confidentiality and security of all personal health information in its custody or under its control. This includes protecting personal health information from theft, loss, and unauthorized collection, use, or disclosure, by applying the following safeguards:
- Regularly reviewing access logs to records of personal health information;
- Restricting access to records of personal health information to authorized personnel who need access to perform their duties and functions;
- Conducting audits and completing investigations to ensure Health and Wellness Services personnel are not accessing more personal health information than is necessary to do their jobs;
- Training Health and Wellness Services personnel on relevant access and privacy policies and procedures;
- Providing secure facilities, locked cabinets, and secure methods for storing and disposing of personal health information;
- Requiring all personnel to sign a confidentiality agreement that outlines their obligations and renewing these agreements on a regular basis;
- Only retaining personal health information for as long as required to achieve the purposes for which it was collected, or as permitted or required by PHIPA; and
- Securely disposing of personal health information.
Access and Correction
For information about how to submit an access or correction request under PHIPA, please refer to the University’s Procedure for Handling Access and Correction Requests.
Complaints to Privacy Regulator
Individuals who have concerns about the handling of their personal health information may file a complaint with the Office of the Information and Privacy Commissioner of Ontario (IPC). The IPC’s contact information is as follows:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario
M4W 1A8
Telephone: 1(800)387-0073
Fax: (416)325-9195
Email: info@ipc.on.ca
Contact
General Counsel is the designated contact person for Health and Wellness Services. To discuss matters related to this Notice, contact General Counsel at:
Office of the General Counsel
935 Ramsey Lake Rd, L1130
Sudbury, ON
P3E 2C6