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CHIRS' Personal Health Information Policy
CHIRS
collects and uses your Personal Health Information (PHI) to provide the
best possible service. We recognize the importance of privacy and the
sensitivity
of your PHI. We are committed to ensuring that your privacy is
protected through practices and policies that relate to collecting,
using, sharing, and keeping PHI consistent with Ontario's Personal
Health Information Protection Act, 2004.
Why does CHIRS need your PHI?
Personal health and financial information are collected and used in order to:
- Determine your eligibility for service, including subsidy;
- Determine your ability to make your own decisions;
- Provide
you with individualized services/treatment that relate to your needs;
CHIRS has a team approach.
Our staff and volunteers are provided access to your PHI in order to
provide service and/or carry out their assignments. However, the amount
of PHI made available is limited to what is needed to carry out the
assignment or to provide the service;
- Maintain a list of applicants who are waiting for CHIRS services;
- Satisfy legal, regulatory, and government reporting requirements;
- Improve the quality of our services, including the management of risk;
- Teach students and other professionals;
- Raise funds in order to improve our services;
- Conduct research to improve our knowledge in acquired brain injury.
What PHI does CHIRS collect and keep?
CHIRS collects and keeps:
- Your PHI relating to the service(s) provided by CHIRS or being requested by you;
- Reports on your goals, assessments, progress, support needs, and medical and psychological information
that relate to your service plan;
- PHI about you received from other sources, where the information helps us have a better understanding
of your needs and your progress;
- Your PHI profile, which provides important contacts, your photograph, and PHI for everyday staff use
and for use in an emergency;
- Recordings of you participating in activities and/or receiving treatment.
How does CHIRS collect your PHI?
With your consent, CHIRS collects your PHI in the following ways:
- PHI is collected in the ABI Community Referral form submitted by you or the person acting on your behalf;
- PHI is collected during your screening interview with the CHIRS Intake and Assessment team;
- We receive information from other agencies and organizations that have either provided service to you
in the past or are continuing to do so. This may include assessments shared through a secure electronic system;
- We may also receive PHI from other health professionals, service providers, and family members - both
written and verbal;
- PHI is also accessed in ConnectingOntario by authorized CHIRS staff when needed for the purpose of
determining eligibility or service provision;
- We may record you (photographs, video, and audio).
When does CHIRS disclose PHI?
CHIRS discloses your PHI when you give us your consent. For example:
- When making referrals on your behalf for additional services or to apply for financial benefits;
- When you identify others who are involved in your support;
- When promoting CHIRS programs and services;
- In the course of running a social media program in which you have chosen to participate;
- When submitting generalized assessments to Ontario Health.
CHIRS may disclose your PHI without your consent if we are required or authorized to do so by law. For example:
- In the event of an emergency where you need timely health care, unless you have told us not to;
- When you are at risk of serious harm or your actions would put someone at risk of serious harm. This
includes reporting certain communicable diseases to public health authorities;
- To meet government, regulatory and legal reporting requirements.
Your Choices
- You may withdraw your consent for some of the above-mentioned use/disclosure;
- You may direct us to share or not to share some or all of the PHI about you to certain people or agencies;
- You may ask us not to take any recordings of you or you may choose not to pose for a recording (still
or video) at a particular moment;
- In certain circumstances, limiting our ability to collect information may impede our ability to provide
comprehensive service;
- You may have access to and seek correction of your PHI.
The Security of your Personal Health Information
CHIRS takes steps to:
- Ensure that everyone who works or performs services for us protects your privacy and uses your PHI
only for the purposes to which you consented;
- Transmit PHI in a secure fashion, whether written or verbal. Information may be faxed, mailed, emailed,
or sent to a secure electronic system such as Ontario Health;
- Protect your PHI from theft, loss, and unauthorized access, copying, modification, use, disclosure,
and disposal;
- Ensure authorized staff are trained and complete audits and investigations to monitor and manage our
privacy compliance.
Limits to Confidentiality
CHIRS
services are offered in both private and public spaces, including the
support you may receive within the community. Your actions and presence
in
public areas cannot reasonably be held in confidence. Reasonable
efforts will be made by CHIRS to identify clients in advance who do not
want to be recorded (via audio, video, or still image) and CHIRS staff
will assist in facilitating others to respect those
wishes.
Contact CHIRS for More Information
For
more information about the CHIRS privacy protection practices or to
raise a concern about our practices, contact our Privacy Officer,
Michele Graham
62 Finch Avenue West, Toronto, Ontario, M2N 7G1
E-mail: micheleg@chirs.com telephone: 416 240-8000
If you believe your privacy rights have been violated, you can file a complaint with:
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400, Toronto, Ontario, M4W 1A8
Telephone: 416 326-3333
Additional information is on their web site:
www.ipc.on.ca
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