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How to Run A Hospital within the New Privacy Landscape

How to Run A Hospital within the New Privacy Landscape. Ann Cavoukian, Ph.D. Information & Privacy Commissioner/Ontario. The Access Group Roundtable on Health Sector Issues April 29, 2005. Why Bother???.

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How to Run A Hospital within the New Privacy Landscape

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  1. How to Run A Hospital within the New Privacy Landscape Ann Cavoukian, Ph.D. Information & Privacy Commissioner/Ontario The Access Group Roundtable on Health Sector Issues April 29, 2005

  2. Why Bother??? • Privacy is fundamental to excellent information management practices and patient care – they are complimentary. • Privacy has always been a consideration --- our obligation to patients is now codified. • Legal test --- Reasonableness.

  3. Research • A health information custodian may use PHI for research purposes but only if the custodian has a research plan approved by a research ethics board. Research Ethics Board to consider: • Whether research could be accomplished without using the PHI. • Whether appropriate safeguards will be in place. • Public interest in conducting the research. • Whether obtaining consent directly is impractical.

  4. Fundraising • Adopt an opt out model in order to comply with fundraising provisions: • Stewardship • Oversight • Ongoing rigor & monitoring

  5. Lock Box Provisions Work Group: • Clinical Scenarios • Provincial Pilot – Consent Management • Physician involvement is key • Experience at TOH

  6. Compliance: Be Practical Do’s & Don’ts • Place whiteboards in non-public areas • Use the P.A. system accordingly • Don’t discuss confidential information in public areas. • Do not leave PHI such as charts, reports, lists etc in places where they can be viewed. • Do not leave the computer terminal with PHI readily visible

  7. Compliance: Be Practical Do’s & Don’ts • Never store PHI on lap tops, PDAs or desktops. • All PHI must be stored on the network. • Never e-mail PHI. • Access only information you require. • Remember to log off

  8. Compliance: Be Practical Do’s & Don’ts • Don’t reveal confidential information to others without a need for them to know it. • Keep your password to yourself. • Shred all papers that contain PHI when no longer in use. • Wear your ID badge at all times.

  9. Program Elements • Privacy Committee • Privacy Policy • Training & Orientation modules • Infonet (Intranet) Page for Staff & Physicians • Web Site for Patients & Partners • Notice to Patients --- posted at all key access points

  10. Tools and Templates Make Compliance Easy: Templates for: • Consent • Release of Information • Use of Data bases, • Affiliation Agreements, • Research, • Tools for Physicians

  11. Communication is Key Communication Plan: • CEO Letters, • Articles in Journals, • Brochures, • Program Launch, • Branding Privacy • CD ROMs • Videos • Web Based Education

  12. Compliance Reorganization of: • Risk Management • Legal • Privacy • Communications • Public Relations

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