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Privacy

PERSONAL HEALTH INFORMATION AND YOUR HEALTH RECORD

Hospice Niagara is subject to the requirements of the Personal Health Information Protection Act, 2004 (PHIPA), and all other related privacy legislation. 

The Personal Health Information Protection Act (PHIPA) is consent-based legislation which governs the manner in which personal health information may be collected, used, accessed, disclosed and disposed.

Hospice Niagara is committed to respecting and maintaining the privacy of your personal health information and maintains ongoing PHI privacy compliance through policies, procedures, preventative measures, training, confidentiality agreements, regular audits of access to client records, security controls and safe practices.

Your health record includes information relevant to your health and may include your date of birth, contact information, health history, family health history, details of your physical and mental health, the care and support you have received, results from tests and procedures, and information from other health care providers. 

Your record is our property, but the information belongs to you.

ACCESS

Your personal health information belongs to you and as a custodian of that information, we hold it in trust for you. You have the right to;

  • Have your personal health information kept confidential, with limited exceptions;
  • Access your personal health information, with limited exceptions;
  • Request a correction of incomplete or inaccurate information contained within your health record

Should you wish to see the full contents of an information file, you must make a formal written request and mail or deliver it to:

Hospice Niagara
2 – 403 Ontario Street
St. Catharines, ON  L2N 1L5
ATTN: Privacy Officer

If you wish to view the original record, one of our staff members must be present. If you need a copy of your health record, please ask your health care provider or our Privacy Officer who will explain the process. A copy will be provided at a reasonable fee. In rare situations, you may be denied access to some or all of your record (with any such denial being in accordance with applicable law).


COLLECTION, USE AND DISCLOSURE

We collect your personal health information under the authority of the Personal Health Information Protection Act, 2004 (PHIPA). The personal health information that we collect from clients may include your date of birth, contact information, health history, family health history, details of your physical and mental health, the care and support you have received, results from tests and procedures, and information from other health care providers. 

Every effort is made to keep your record accurate and up-to-date. Please let us know if you disagree with what is recorded, and in most cases we will be able to make the change or otherwise we will ask you to write a statement of disagreement and we will attach that statement to your record.  

We collect, use and disclose your health information to:

  • Treat and care for you
  • Provide services to you
  • Provide client surveys to you
  • Fundraise for Hospice Niagara’s programs and services (only your name and contact information are shared with our Fund Development team, unless you tell us not to provide this information)
  • Update you of upcoming events, activities and programs
  • Coordinate your care with your other health care providers including through shared electronic health information systems such as Ontario Health Teams, Ontario Laboratory Information Systems (OLIS), HealthLinks, Connecting Ontario, ClinicalConnect, InfoAnywhere, and local, regional and provincial programs 
  • Deliver and evaluate our programs
  • Plan, administer and manage our internal operations
  • Be paid or process, monitor, verify or reimburse claims for payment
  • Conduct risk management, error management and quality improvement activities
  • Educate our staff and students
  • Dispose of your information
  • Seek your permission (or permission of a substitute decision maker) where appropriate
  • Respond to or initiate proceedings
  • Conduct research (subject to certain rules)
  • Compile statistics
  • Allow for the analysis, administration and management of the health system
  • Comply with legal and regulatory requirements
  • Fulfill other purposes permitted or required by law

Our collection, use and disclosure (sharing) of your personal health information is done in accordance with Ontario law.  Your request for care implies consent for our collection, use and disclosure of your personal information for purposes related to your care as noted above.  All other purposes would require your express consent.

Hospice Niagara relies on community donations to provide programs and services at no cost to people and families in Niagara.  Hospice Niagara may share client names and contact information with our Fund Development team to contact you for support, unless you tell us not to provide this information.  

You have a right to make choices and control how your health information is collected, used, and disclosed, subject to some limits.

You may make your own decisions if you are “capable”. Your health care provider will decide if you are capable based on a test the law sets out. You may be capable of making some information privacy decisions and not others. If you are not capable – you will have a substitute decision-maker who will make your information decisions for you. Who can act as a substitute decision-maker and what they have to do is also set out in law.

We assume that you have given us your permission (your consent) to use your information, unless you tell us otherwise. We may also collect, use and share your health information in order to talk with other health care providers about your care unless you tell us you do not want us to do so.

You have the right to ask that we not share some or all of your health record with one or more of our team members or ask us not to share your health record with one or more of your external health care providers (such as a specialist). This is known as asking for a “lockbox”. If you request restrictions on the use of and disclosure of your health record, a member of our team will explain your choices and potential repercussions for those options.

There are other cases where we are not allowed to assume we have your permission to share information.  We may need permission to communicate with any family members or friends with whom you would like us to share information about your health (unless someone is your substitute decision-maker). For example, we will also need your permission to give your health information to your insurance company. If you have questions, we can explain this to you.

When we require and ask for your permission, you may choose to say no. If you say yes, you may change your mind at any time. Once you say no, we will no longer share your information unless you say so. Your choice to say no may be subject to some limits.

There are cases where we may collect, use or share your health information without your permission, as permitted or required by law. For example, we do not require your permission to use your information for billing, risk management or error management, quality improvement purposes. We also do not need your permission to share your health information to keep you or someone else safe (it’s called to eliminate or reduce a significant risk of serious bodily harm); or to meet reporting obligations under other laws such as for health protection of communicable diseases. 

HOSPICE NIAGARA PRIVACY PRACTICES AND GUIDING PRINCIPLES

The Canadian Standards Association has developed 10 Privacy Principles that underpin both Canadian and Ontario privacy legislation. These form the basis of our Privacy Policy and how Hospice Niagara collects, uses, discloses and safeguards the personal information (including personal health information) we hold about you.

When you visit our website, contact us, participate in one of our programs, become a client, or make a donation to support our activities, we are committed to protecting your privacy rights and your personal information. We value your trust and recognize that maintaining this trust requires that we be open and accountable in our treatment of the personal information that you choose to share with us. We do not trade, rent or sell the names of the people we serve or our valued supporters.

The following principles reflect our pledge to safeguard your Personal Information pursuant to this Privacy Policy.

1. We are accountable for your personal information.

“Personal Information” is any information that can be used to distinguish, identify or contact a specific individual. This information includes whether an individual has donated to Hospice Niagara, how much has been donated and an individual’s private contact information.

We keep the personal information that you provide to us in strict confidence.

Hospice Niagara is bound by confidentiality. We protect your information from loss or theft and make sure no one accesses your information if they are not involved with your care or allowed as part of their job.  Administrative, technical and physical safeguards are in place to ensure that the information is not accessed, disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed. Individuals may access their personal information at any time to ensure that it is correct and current.

We only disclose your information to Hospice Niagara on an as needed basis, to certain service providers to conduct activities on our behalf, or with your consent.  Where we choose to have certain service providers conduct activities on our behalf (such as some fundraising and processing services), we select the service providers very carefully and take all reasonable precautions to ensure that the service provider protects your personal information.

2. We collect, use and disclose personal information for the purposes that we identify to you.

When Hospice Niagara collects personal information directly from individuals, Hospice Niagara identifies the purposes for which personal information is collected at or before the time of collection. These purposes include: fundraising, the administration of the donations, providing information about the activities of Hospice Niagara, compliance with legal and regulatory requirements and to ask for support in our mission to improving the end-of-life journey, providing continuous, person-centered care while advancing knowledge and partnerships within Niagara. 

Hospice Niagara relies on community donations to provide programs and services at no cost to people and families in Niagara.  Hospice Niagara may share client names and contact information with our Fund Development team to contact you for support, unless you tell us not to provide this information.  

3. We obtain your consent to collect, use or disclose your personal information.

We collect, use or disclose your personal information with your permission. Your permission may be expressed orally, in writing or may be implied, and you may give it to us orally, electronically or in writing. You may limit or opt-out of future contact by Hospice Niagara by contacting us at info@hospiceniagara.ca.

4. We limit the collection of your personal information.

We limit the collection of personal information to that which is necessary for the purposes identified. Personal information will be collected only by fair and lawful means.

5. We limit the use, disclosure and retention of personal information.

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with consent or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. Hospice Niagara does not trade, rent or sell any Personal information to third parties.

Hospice Niagara’s web pages contain online forms that allow visitors to make a donation. The personal and credit card information provided on these secure forms is used only to process these donations. 

6. Accuracy of personal information.

Every effort is made to keep your record accurate and up-to-date. We also rely on individuals, such as donors or clients, to provide us with accurate and up-to-date personal information. To change or modify any personal information previously provided to Hospice Niagara please submit a request in writing to the contact information listed below.

7. We safeguard your personal information.

Personal information is protected with administrative, technical and physical safeguards appropriate to the sensitivity of the information. Hospice Niagara is committed to maintaining the confidentiality of your personal information. In addition to safeguards in place, Hospice Niagara maintains ongoing privacy compliance through policies, procedures, preventative measures, audits, breach protocols and safe practices.

We use password protocols and reputable secure websites to protect personal information we receive when an online donation is made. Our software is routinely audited and updated to maximize protection of such information.

8. We are open about our privacy practices.

We are open about our privacy policies and procedures. We make reasonable efforts to inform individuals about our policies and procedures, the purposes for which we collect, use, or disclose personal information, including personal health information, and how to access your personal information. You may request a print version of our Privacy Policy using the contact information listed below.  

9. We allow you to access your Personal Information.

You may ask us whether we hold any personal information about you. You can see that information and ensure that it’s accurate by sending a formal written request to the Privacy Officer at the contact information listed below.  

10. Compliance with our privacy practices.

If you are concerned about the Hospice Niagara’s compliance with our Privacy Policy, please contact the Privacy Officer at the contact information listed below.  

We will investigate all complaints. If a complaint identifies a gap in compliance, we will take appropriate steps to remedy the situation, including changing our policies and practices if necessary.

Questions, comments and concerns regarding the handling of personal information may be directed in writing to the Privacy Officer at Hospice Niagara via the contact information listed above.  

For public affairs inquiries, please contact Hospice Niagara’s Marketing and Communications Department by sending an email to news@hospiceniagara.ca

If you wish to limit or opt-out of future contact, please submit a request in writing to the address listed above or email info@hospiceniagara.ca

If, after contacting us, you feel that your concerns have not been addressed to your satisfaction, you have the right to complain to the Information and Privacy Commissioner of Ontario.  The Commissioner can be reached at:

Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
1-800-387-0073
1-416-325-9195 (fax)
or visit the IPC website via www.ipc.on.ca

CONTACT US:

Hospice Niagara
2 – 403 Ontario Street, St. Catharines, ON  L2N 1L5
Attention: Privacy Officer
Phone: (905) 984-8766   Fax: (905) 984-8242
Email: privacy@hospiceniagara.ca