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Accountability

Accountability for collection, use, disclosure and protection of personal information in the custody or under the care and control of Health PEI rests with the CEO, even though other individuals within the organization are responsible for the day-to-day collection, use, disclosure and protection of personal information.

Health PEI identifies the purposes for which it collects personal information prior to the time the information is collected, in accordance with Federal and Provincial legislation.

The knowledge and consent of the individual about whom the personal information relates are required for the collection, use or disclosure of personal information.

The individual from whom the personal information is collected shall be informed of:

• the purpose for which the personal information is collected;
• the authority for the collection; and
• contact information for the FOIPP Coordinator so that the individual’s questions about the collection can be answered.

Written, implied or verbal consent shall be obtained, as appropriate, from the individual or authorized representative, depending upon the nature of the circumstances, for any collection, use or disclosure of personal information.

Health PEI staff must use discretion in obtaining consent where circumstances suggest that capacity or safety may be an issue.

Health PEI limits the collection of personal information to that which is necessary for its identified purposes through fair and lawful means.

Health PEI does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

• Health PEI staff, physicians, students and volunteers, may only have access to personal information required by them for the performance of their duties.
• Personal information is retained only as long as necessary to fulfill the purpose for which it was collected or as required by legislation.
• Health PEI will establish and comply with a retention and destruction schedule for personal information under its custody or care and control.
• Health PEI will disclose personal information in a manner consistent with legislation, including but not limited to:

(i) the purposes for which the information was collected or a consistent purpose;
(ii) meeting legislated requirements, or the requirements of an agreement authorized by legislation; or
(iii) purposes of research and in compliance with section 39 of the FOIPP Act.

Where disclosure is requested for the purpose of research, the PEI Research Ethics Board bust review and grant approval for the research.

4.5.6 When disclosure is required for other purposes, Health PEI will transform personal information into non identifying information in the following manner:
(i) direct identifiers such as name, full address, personal health number or health service provider number are removed, encrypted or truncated.
(ii) sensitive data elements such as date of birth, date of admission, date of discharge, postal code and clinical procedure are removed, encrypted or truncated, if when taken together, or in combination with other data elements, they reasonably lead to identification of the individual.