St. Thomas Elgin General Hospital (STEGH) is responsible for personal health information under our control. We are committed to a high standard of privacy for our information practices. The hospital has adopted the 10 principles set out in the Personal Health Information Protection Act, 2004.
Principle 1 - Accountability for Personal Health Information: The hospital is responsible for personal information under its control and has designated individuals (Director of Quality, Risk and Safety and Privacy Officer) who are accountable for compliance. STEGH is complying by implementing policies and procedures for: protecting your personal health information, including information relating to patients, staff, and agents; adhering to policies and procedures when receiving and responding to complaints and inquiries; training and communicating to staff and agents information about privacy policies and practices; developing plans and communicating to our patients, families, members of the public and key hospital stakeholders.
Principle 2 - Identifying Purposes for the Collection of Personal Health Information: The hospital will identify the purposes for which personal health information is collected at or before the time of collection. These purposes will be conveyed by means of posters, brochures, web sites and by direct contact with the Privacy Office. Primarily, personal health information is used to deliver patient care, for administration, in research, teaching, statistics, fundraising, and to meet legal and regulatory requirements. Patients imply consent when they present for treatment and receive an explanation. Unless a new purpose is legally required, consent must be obtained before the information can be used.
Principle 3 - Consent for the Collection, Use and Disclosure of Personal Information: An individual's knowledge and consent is required to collect, use, or disclose personal health information. The form of consent - express or implied - and the way it is sought - in writing or orally - may vary depending upon the circumstances and sensitivity of the information. Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. Personal health information can be collected, used, or disclosed without the knowledge and consent of the individual; for example, legal, medical, or security reasons may make it impossible or impractical to seek consent.
Principle 4 - Limiting Collection of Personal Health Information: Only information necessary for the purposes identified may be collected, by fair and lawful means.
Principle 5 - Limiting Use, Disclosure and Retention of Personal Information: Personal health information may be used only for the purposes for which it was collected, except with consent or as required by law. The hospital will document any new purpose and may require consent from the individual. The information is retained only as long as necessary, and destroyed in accordance with legislation, hospital policies, guidelines and procedures.
Principle 6 - Ensuring Accuracy of Personal Health Information: The hospital will make every effort to ensure the information they hold is accurate, complete and up-to-date. Patients have the right to challenge the accuracy of the information.
Principle 7 - Ensuring Safeguards for Personal Information: The hospital applies security safeguards appropriate to the sensitivity of personal health information to aim to protect it against loss, theft, unauthorized access, disclosure, copying, use, or modification, regardless of its format. Protection may include physical measures (i.e., locked filing cabinets and restricted access), organizational measures (limiting access on a "need-to-know" basis) and technological measures (use of passwords, encryption and audits). Hospital staff and agents will be required to sign a confidentiality agreement as a condition of employment, appointment, or agency. Those with access to electronic health records must sign individual user agreements.
Principle 8 - Openness About Personal Information Policies and Practices: The hospital makes information about their privacy policies and practices readily available, in a form that is generally understandable. This will include:
- contact information for the hospital's Privacy Office, to which complaints or inquiries can be forwarded;
- means of gaining access to personal health information held by the hospital;
- a description of the type of personal health information held by the hospital, including a general explanation of its use;
- brochures or other information explaining the hospital’s policies, standards, or codes; and, what personal health information is made available to related organizations.
Principle 9 - Individual Access to Own Personal Information: Upon request, within a reasonable time and at a reasonable cost, an individual will be informed of the existence, of his or her personal information and will be given access to it. They can challenge its accuracy and completeness and have it amended as appropriate. Exceptions to access will be limited and specific, with reasons provided upon request. This may include information that is prohibitively costly to provide; refers to other individuals; cannot be disclosed for legal, security, or proprietary reasons, or is subject to solicitor-client or litigation privilege.
An individual must provide sufficient information to permit the hospital to identify the existence of personal health information, including details of third-party recipients.
Principle 10 - Challenging Compliance with the Hospital's Privacy Policies and Practices: An individual will be able to address and challenge issues concerning compliance with this policy to the Director of Quality, Risk and Safety or Privacy Officer. The hospital will put procedures in place to receive and respond to complaints or inquiries about their policies and practices relating to the handling of personal health information. The hospital will investigate all complaints. If a complaint is justified, the hospital will take appropriate measures, including, if necessary, amending their policies and practices.