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Privacy Toolkit

OTN takes the privacy of health and other information it may have access to very seriously and is committed to protecting it in ways that meet privacy law and industry standards.

This Toolkit is provided for general information and consideration purposes only. These resources were largely developed to help OTN meet the requirements of the Personal Health Information Protection Act (PHIPA), S.O. 2004, and Regulation 329/04, while also supporting OTN’s commitment to transparency. Please visit OTN’s Privacy Centre for further information, tools and best practices.  The Privacy Team’s  Integrated Privacy Policy Framework as well as OTN’s Annual Privacy Report are also available for your information and learning.

Privacy Impact Assessment

A privacy impact assessment is a detailed assessment undertaken to identify the actual or potential effects that a proposed project will have on the privacy of those whose personal health information (PHI) is included in the proposed project. A privacy impact assessment also identifies ways in which privacy risks may be mitigated. Additionally, privacy impact assessments may be used to ensure alignment with Privacy by Design principles.

OTN must conduct formal privacy impact assessments (in combination with a threat and risk assessment when required) when acting in its capacity as a Health Information Network Provider (HINP) to Health Information Custodians (HIC), as required under PHIPA. OTN must comply with all privacy impact assessment requirements identified in its project funding agreements with Canada Health Infoway and other funding partners. For initiatives involving consumer-based health services, where only personal information is held by OTN, OTN will conduct a privacy impact assessment or privacy review for any new technology and/or service, or new use of personal information where it is planned for collection.

OTN will publish summaries of completed privacy impact assessments conducted for various programs it manages. OTN publishes Primary Impact Assessment (PIA) summaries to ensure transparency with its members, users, the public, and those individuals who may be the subject of the personal and/or personal health information collected, used, disclosed, retained or disposed of in relation to OTN’s products or services. OTN also publishes these summaries to ensure compliance with the requirements for health information network providers under Ontario Regulation 329/04 (s. 6(3)). Without the express written consent of OTN. the summaries or the content therein may not be copied, used, or redistributed outside of the purposes identified.

Summaries to date include:

 

Resources

Privacy - Resource Materials

Emergency Services Privacy and Security Considerations
Emergency Services Virtual Critical Care Privacy and Security Considerations
IPC Tutorial for protecting PHI on mobile & portable devices
Poster - Authorized viewers of PHI
Poster - Clean desk principles
Poster - Faxing
Poster - Protecting the privacy of your PHI (office/e)
Poster - Protecting the privacy of your PHI (studio/e)
Poster - Protecting the privacy of your PHI (office/fr)
Poster - Protecting the privacy of your PHI (studio/fr)
Poster - Unique passwords
Privacy Facts 1: Avoid connecting before the scheduled time
Privacy Facts 2: You could still be connected
Privacy Facts 3: Misdirected faxes and privacy breaches
Privacy Facts 4: Connecting in error impacts patient privacy
Privacy Facts 5: Lack of physical privacy and privacy breaches
Privacy Facts 6: Emergency Telemedicine services have unique privacy challenges
Privacy Facts 7: Off-net clinical activity privacy & security considerations
Privacy Facts 8: Preventing misdirected FOIP
Privacy Facts 9: OTN Privacy Awareness For Adobe® Acrobat® Connect ™ Pro Webconferencing
Privacy Facts 10: Privacy Considerations for Posting to the OTN Telemedicine Directory
Privacy Facts 11: Tips for using "guest link" for Personal Videoconferencing
Privacy & Security Facts 12: Privacy in a Virtual and Portable Telepresence - Challenges in a mobile or wireless environment
Privacy & Security Facts 13: Emergency TM services have unique privacy & security considerations
Top 10 privacy tips

To contact OTN’s Privacy Team:
Email: privacy@otn.ca
Phone: 1-855-654-0888
Mail: Ontario Telemedicine Network
        438 University Avenue, Suite 200
        Toronto, ON  M5G 2K8

To contact the Office of the Information and Privacy Commissioner of Ontario:

Email: info@ipc.on.ca
Toronto Area:  416-326-3333
Toll Free: 1-800-387-0073   
TDD/TTY: 416-325-7539
Mail: 2 Bloor Street East, Suite 1400
        Toronto, ON  M5V 1A8