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Statement of Information Practices

INTRODUCTION

The Alliance for Healthier Communities is Ontario’s voice for community-governed primary health care. The Alliance represents over one hundred members, including Ontario’s Community Health Centres (CHCs), Aboriginal Health Access Centres (AHACs), Community Family Health Teams (CFHTs), and Nurse Practitioner-Led Clinics (NPLCs). The Alliance shares a strong commitment to advance health equity and recognize that access to health is a fundamental human right. Alliance members work hand in hand with those they serve. Each is governed by a board made up of clients and community representatives. Community governance enables health services to be more oriented towards what community members identify as their most important needs.

The Alliance, as well as our members, believe good health is much more than something you get in a medical clinic. We believe that better health begins in our homes, in our schools, in our workplaces, and in the communities where we live. Our goal is therefore to work towards equitable health and wellbeing for individuals, families and our communities.

OUR ROLE

The Alliance comes into contact with personal information (PI) when it collects, uses, and discloses employees’ PI to manage the employment relationship, it collects contact information and credit card details from people it registers for conferences and events.

The Alliance has access to personal health information when it helps members set up and use the electronic medical record (EMR) system and as the service provider of the Business Intelligence Reporting Tool (BIRT) solution. BIRT is an innovative award-winning business intelligence software solution developed to support members in the areas of accountability reporting to funders, services planning and evidenced-based clinical decision making. The Health Information Custodians (HICs) remain fully accountable to the individuals receiving health care for the privacy practices associated with personal health information. The Alliance does not make any independent decisions concerning the handling of personal health information. It complies with the privacy practices of the Health Information Custodians on whose behalf it acts as an Agent as defined in the Personal Health Information Protection Act, 2004.

The Alliance is not a Health Information Custodian (HIC). Accordingly, if an access request is made to the Alliance for PHI, it will direct the client to the appropriate HIC(s) to respond to the request.

For more information about the Alliance’s privacy policies and roles, please contact our Privacy Officer.

SECURITY AND CONFIDENTIALITY OF INFORMATION IN THE CUSTODY OF THE ALLIANCE

Protecting privacy involves giving and respecting person’s choices about how information about them can be collected, used and disclosed. Privacy breaches often result in people feeling shame or embarrassment because their families, friends, communities or strangers learn things about them that they did not want shared. Conversely, by feeling secure that their privacy will not be violated, clients engage more fully in the health care system. Protecting privacy is therefore inherent in the Alliance and its Members’ vision of health and wellbeing.

The Alliance protects PI and PHI in its custody with technical, administrative, and physical safeguards that are appropriate to the information’s sensitivity, the format in which it is held, and the related privacy risks. These include confidentiality agreements, privacy impact and threat-risk assessments, staff training, security software and encryption protocols, and other controls.

All information is secured against theft, loss, unauthorized collection, use or disclosure, unauthorized copying, modification or disposal using industry best practices. All staff have signed a Confidentiality Agreement/Pledge and completed applicable privacy and security awareness training and have formally agreed to comply with any additional privacy-related requirements and restrictions established by the Alliance. Personnel will not access PI/PHI unless they need to in order to perform their roles and are authorized to do so. The Alliance ensures that the all information is retained, transferred or disposed of in a secure manner. These practices and safeguards are reasonable and consistent with evolving privacy and security standards and best practices.

CONTACT

If you have questions or complaints regarding our privacy practices, please contact us:

c/o Chief Privacy Officer
Alliance for Healthier Communities
Suite 500, 970 Lawrence Ave West
Toronto, ON, M6A 3B6
Email: privacy@allianceON.org
Telephone: 416-236 2539

COMPLAINTS

You have the right to contact the Office of the Information and Privacy Commissioner of Ontario if you have a complaint about our privacy policies or practices. The Commissioner can be reached at:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, ON, M5G 2C8
Telephone: 416-326-3333 or 1-800-387-0073
Fax: 416-325-9195
Website: www.ipc.on.ca

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