Respecting Your Privacy
Strathmere Lodge is committed to protecting the privacy of residents and ensuring the security of their personal health information. We also maintain the confidentiality of health care records. Our commitment extends to individuals who provide personal information to us as defined by the Personal Health Information Protection Act (PHIPA).
Our practices regarding the collection, use, and retention of personal information are guided by responsible policies and procedures, and are compliant with all applicable legislation.
What is "Personal Health Information"?
The Personal Health Information Protection Act, or the “PHIPA”, is the provincial law that governs the collection, use and disclosure of personal health information. Its purpose is to keep personal health information confidential and secure, while allowing for the effective delivery of health care. Personal Health Information, includes any identifying information about an individual’s health or health care, such as:
- clinical information, for example lab or X-ray results;
- medication information,
- health history,
- one’s health provider, and
- one’s health card number.
Under the PHIPA, Strathmere Lodge is a “Health Information Custodian”. The PHIPA prescribes certain obligations on Health Information Custodians to protect personal health information and to collect and use it within defined circumstances. The obligations include the following broad categories:
- responding to requests for access to, and correction of, records of personal health information;
- ensuring transparency of information practices;
- the proper collection, use and disclosure of personal health information,
- maintaining personal health information security, and
- privacy breach management.
The “agents” of Health Information Custodians share these obligations. This includes employees of the long-term care or retirement home, as well as any volunteers who have any access to personal health information, plus persons contracted to provide services to the Home who have access to personal health information.
Collection, Use, and Disclosure
Strathmere Lodge's collects personal health information about our residents, either directly from the resident or from a person acting on their behalf. The information that we collect may include, for example, resident photographs (for identification purposes), name, date of birth, address, health history, and records of the care a resident receives in our Home. We may also collect personal health information from other sources, such as a previous health care provider, if this information is needed by us to provide residents with necessary treatment and care.
We use and disclose resident personal health information for a variety of reasons, as outlined below, all of which are permitted by legislation. When we use personal health information for resident care, only the staff members involved in that care may access the information. Strathmere Lodge uses and discloses personal health information to:
- Treat and care for our residents
- Conduct risk management activities
- Educate and orient new staff
- Comply with legal and regulatory requirements
- Plan, administer and manage internal operations
- Conduct quality improvement activities
- Fulfill other purposes permitted or required by law
We will not use or disclose your personal health information for any marketing or fundraising purposes.
Security of Personal Health Information
We are committed to keeping resident information safe and confidential. Strathmere Lodge has taken steps to protect personal health information from theft, loss and unauthorized access, copying, modification, use, disclosure and disposal. The protection of Personal Health Information includes many elements, ranging from physical safeguards (such as locked filing cabinets and restricted access to offices where personal health information is held), to technical safeguards (such as the use of passwords, encryption, and audits), to administrative safeguards (such as policies and procedures, employee education, and the use of confidentiality agreements with our agents).
Access and Correction
As a resident you may access and correct your personal health information, or withdraw your consent for some of the above uses by making a simple request to your Administrator (subject to legal exceptions, such as where disclosures are required by law). You will be asked to put your request in writing, to enable us to verify the existence of the record in question and to locate it for you. We will respond to access requests within the timeframes set by the PHIPA, and at a reasonable cost.
When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Strathmere Lodge will correct the information as required. Otherwise, the individual may require that a statement of disagreement be attached to the record of personal information.
Consent is required for the collection, use, and disclosure of personal health information. In general, a custodian who provides health care, such as a long-term care or retirement home, is permitted to collect, use and disclose personal health information, on the basis of implied consent, for the purpose of providing health care. This consent extends to the agents of the home, and other health information custodians with whom we collaborate to provide a resident’s care. For certain matters, including those prescribed by the PHIPA, we will seek express consent from a resident or their substitute decision maker (SDM). Consent for the collection, use, and disclosure of personal health information may be expressly withheld or withdrawn by a resident or their SDM, although such a withdrawal cannot be applied retroactively.
Retention of Personal Information
Strathmere Lodge will retain information, including personal information, for as long as it is needed for the purposes for which it was collected and as permitted by legislation. Strathmere Lodge is subject to the retention policies of the County of Middlesex.
Questions and Information concerning Strathmere Lodge's Privacy Practices
Please contact Strathmere Lodge's Privacy Officer with any questions or concerns you have about this Statement or Strathmere Lodge's manner in which it handles of your personal information. The Privacy Officer for the organization will investigate and respond to your concerns.
Paul Shipway, Privacy Officer, Acting Legislative Services Manager/Clerk
Middlesex County Administration Offices
399 Ridout St. N.
Phone: (519) 434-7321 ext. 2250
Individuals may also direct concerns or complaints regarding Strathmere Lodge's compliance with the Personal Health Information Protection Act to the Information and Privacy Commission of Ontario (IPC). The IPC is responsible for making sure that privacy law is followed in Ontario. For more information about your privacy rights, or if you are unable to resolve an issue directly with our Privacy Contact and wish to make a complaint, contact:
Information and Privacy Commission of Ontario
2 Bloor Street East, Suited 1400
Toronto, Ontario M4W 1A8
Toll-free (in Ontario): 1-800-387-0073
Fax: (416) 326-9195