Privacy and Personal Health Information

What is personal health information?

Personal Health Information (PHI) is recorded information about a person, including demographic and assessment information related to physical and mental health status, personal and family health history.

Why is my personal health information collected?

As ‘health care custodians’ we collect your health information for the purpose of providing you with our services. Unless you, or an authorized person acting on your behalf tells us not to, we will use this information to develop a service or care-plan with you and to coordinate care amongst other health service providers involved.

Collection, Use & Disclosure of Personal Health Information

Your request for care from us implies consent for our collection, use, and disclosure of your personal health information for the following purposes:

• to provide and assist in the provision of health care to you through our services, programs, and facilities;
• to plan, administer, and manage the operation of our services, programs, and facilities;
• to manage risk and improve the quality and safety of our services and programs;
• to educate or train our agents to provide health care;
• to comply with legal and regulatory requirements; and,
• to fulfill other purposes that are permitted or required by law.

We primarily collect personal health information about you directly from you through our intake and assessment process. We collect only the minimum amount of information required to provide you with our services and coordinate care. At times, we may ask for information from a person close to you (e.g. family member) where it is relevant or appropriate, but we only do so if we have your consent.

From time to time, we may communicate about your care with your other health care providers, including collecting, using, and disclosing your personal health information through electronic medical information systems (sometimes called electronic health records, eHealth records, electronic medical records, etc.). If you would like more information about the electronic medical information systems we use, please speak with our Privacy Officer.

Any uses of your personal health information other than those mentioned above would require your express consent, for example speaking with your family or friends.

Storage and Access of PHI Data

Our organization securely stores your personal health information (PHI) using AlayaCare, a third-party database provider managed by Alzheimer Society Ontario (ASO). Access to your PHI is strictly limited to authorized personnel at ASNR, ASO, and AlayaCare. To see how AlayaCare keeps your data safe, you can review their privacy policies here. No other healthcare providers have access to your PHI. We ensure that all data is handled and protected in compliance with Ontario's Personal Health Information Protection Act (PHIPA) and industry-standard security measures.

How do we protect your privacy?

We handle and protect your personal health information in accordance with Ontario’s Personal Health Information Protection Act, 2004 (PHIPA) and any other laws that we are required to follow. We provide training, follow established policies, and take other steps to ensure that our staff and anyone else acting on our behalf protects your privacy.

We also take every reasonable step to ensure that information is protected from theft, loss and unauthorized use or disclosure. Records of personal health information are retained, transferred and disposed of in a secure manner and are reasonably protected against unauthorized copying, modification or disposal.

Your rights and choices

PHIPA provides you with certain rights related to your personal health information under our custody or control. Please communicate with our Privacy Officer for more information related to your rights:

• to see and get a copy of your personal health information;
• to ask us to make corrections to inaccurate or incomplete personal health information;
• to withdraw your consent to our collection and use of your personal health information or its disclosure to other health care providers (subject to certain legal obligations); and,
• to be informed if your personal health information is lost, stolen or improperly accessed.

You have the right to withhold or withdraw your consent at any time to the collection, use or disclose of your personal health in- formation. This decision will not impact the services you receive from the Alzheimer Society of Niagara Region.

You can communicate your wishes directly to us through your Family Support Counsellor or our Privacy Officer.

Please note that we may share personal health information without your consent if we have reasonable grounds to believe that the disclosure is necessary to eliminate or reduce a significant risk of serious bodily harm to you or others, or in situations where we are legally required to do so.

Website Use

The Alzheimer Society may collect and use an individual's IP address, and date and time that the individual accessed our website, to help identify the individual, gather broad demographic information about users of the website, diagnose problems with the Alzheimer Society’s systems, and administer the Alzheimer Society website.

Depending on an individual's browser settings, the Alzheimer Society website may use cookies. A cookie is a tiny element of data that a website can send to an individual's browser, which may then be stored on their hard drive so the website can recognize them when the individual returns to the particular website. We may use cookies to deliver content according to the individual's preferences. If an individual's browser settings do not accept cookies from our website, they may not be able to take advantage of all of the features of the website.

We use “Google Analytics” to collect information about use of the Alzheimer Society website. Google Analytics is a web analytics service that uses cookies to track information about the use of the website such as how often users visit the sites, what pages they visit when they do so, and what other websites they used prior to coming to the Alzheimer Society website. This information is used to improve the Alzheimer Society website. Google Analytics only collects the IP addresses assigned to you on the date you visit the site, rather than your name or other identifying information about an individual. Information collected through the use of Google Analytics is not combined with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Alzheimer Society website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google Analytics stores information on servers in the United States and the governments, courts or law enforcement, or regulatory agencies of the United States may be able to obtain disclosure of Personal Information through the laws of the United States. You can prevent Google Analytics from recognizing you on return visits to the Alzheimer Society website by disabling cookies on your browser. If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit: https://www.google.com/analytics.

Risk of Electronic Communication

The Alzheimer Society of Niagara Region recognizes that email is an important method of communication. However, because of the privacy risks associated with electronic communication providers are not able to communicate with clients via email and text. If a client wishes to be contacted via email, they must express verbal or written consent that they understand the risk of using email with respect to the protection and privacy of their personal health information.

Transmitting information by email poses several risks that you should be aware of. You should not agree to communicate with staff by email without understanding and accepting these risks. The risks include, but are not limited to, the following:

• The privacy and security of email cannot be guaranteed.
• Employers and online services may have a legal right to inspect and keep emails that pass through their system.
• Email may be falsified. In addition, it is very difficult to verify the identity of the sender, or to ensure that only the recipient can read the email once it has been sent.
• Emails can introduce viruses into a computer system and potentially damage or disrupt the computer.
• Email can be forwarded, intercepted, circulated, stored, or even changed without the knowledge or permission of the sender or recipient. Email senders can easily misaddress an email, resulting in it being sent to unintended and unknown recipients.
• Email is indelible. Even after the sender and recipient have deleted their copies of the email, backup copies may exist on a computer or in cyberspace.
• Use of email to discuss sensitive information can increase the risk of such information being disclosed to third parties.
• Email can be used as evidence in court.

Where can I get more information?

To learn more about how personal health information is handled and shared with other Health Service Providers, contact the Privacy Officer at the Alzheimer Society of Niagara Region.

Privacy related contacts

For more information or to raise a concern about our privacy practices, please contact our Privacy Officer:

Roxanne Souter, Privacy Officer
Alzheimer Society of Niagara Region

1-403 Ontario St.
St. Catharines, Ontario L2N 1L5

Ph: 905-687-6856 ext. 537
Email: rsouter@alzheimerniagara.ca

The Information and Privacy Commissioner of Ontario 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 Officer and wish to make a complaint, contact:

Information & Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Ph: (416) 326-3333 • 1-800-387-0073
Email: info@ipc.on.ca
TTY: (416) 325-7539 • Website: www.ipc.on.ca

Consent and Capacity Board

Greater Toronto Area

151 Bloor St. W., 10th Floor
Toronto, Ontario M5S 2T5
Ph: 416- 327- 4142 • TTY: 416-326- 7889
Fax 416-924- 8873 • Website: www.ccboard.on.ca Outside Greater Toronto Area
1-866-777- 7391 • TTY: 1-877-301-OTTY