The Canadian National Institute of Health Inc. (CNIH) promotes a culture where private information is safeguarded. “The CNIH recognizes the right to privacy and the sensitivity of all personal information and we continually take measures to ensure all personal information is handled with great care as reflected through our privacy policy” (CNIH, 2010).
It is the policy of the CNIH to abide by the rules and obligations set out in the legislation, the Information and Privacy Commissioners, and the legal powers and duties of the College of Dental Hygienists of Ontario (CDHO) as stated in the Regulated Health Professions Act (1991) and the Dental Hygiene Act, (1991).
The CNIH abides by the rules and obligations set out in the following documents:
- • The provincial obligations placed on Private Career Colleges under the Freedom of Information & Protection Act (FIPPA, 2008) namely Section 2 of Regulation 459,
- • The Private Career Colleges Act, (PCC, 2005)
- • The provincial obligations stated in the Ministry of Training, Colleges and Universities Act (1990). Updated January 2017.
- • The federal Personal Information Protection and Electronic Documents Act (PIPEDA, 2009),
- •The Personal Health Information Protection Act, (PHIPA, 2004)
- •The Regulated Health Professions Act, (RHPA, 1991) and
- •The federal and provincial Information and Privacy Commissioners’ communiqués, samples are attached to this policy. The CNIH will fulfill its privacy responsibilities as described in the Principles of the Personal Information Protection and Electronic Documents Act.The CNIH has developed and implemented policies and practices to uphold the ten (10) principles set out in PIPEDA including the following:
- •Implementing procedures for protecting personal and personal health information
- •Training students and personnel and communicating information about CNIH policies and practices and
- •Developing information to explain compliance of CNIH to the legislative standards.
Principle 1 – Accountability
The CNIH Privacy Officer is accountable for compliance with these policies and procedures. Employees and students receive training.
The Canadian National Institute of Health Inc. promotes a culture where private information is safeguarded.
According to the requirements of the Information and Privacy Commissioner of Ontario (IPC), effective January 1, 2018, the CNIH Privacy Officer will track privacy breach statistics, and will comply with their request to provide the Office of the IPC with an annual report on the number of privacy breaches within the organization starting in 2019.
Bill 168- An Act to amend the Occupational Health and Safety Act with respect to violence and harassment in the workplace and other matters. This came into effect June 15, 2010. Please see the Act in its entirety located in a binder at reception.
Questions about the compliance of our organization should be directed to the CNIH Privacy Officer, privacyofficer@cnih.ca
Principle 2 – Identifying purposes
The CNIH collects and uses information for a variety of purposes to meet Ministry, Legislative, Regulatory (College of Dental Hygienists of Ontario and College of Medical Radiation Technologists of Ontario) and organizational mandates.
The CNIH Privacy Policy contains mechanisms and schematics that accompany the policies to clarify and identify the purposes for collecting and using private and private health information.
Principle 3 – Consent
The knowledge and informed consent of the individual are required for the collection, use and disclosure of personal information and personal health information. Obtaining informed consent is a pillar of ethical health care practice at CNIH. Additionally, the specifics regarding the Circle of care; Sharing personal health information for health-care purposes (Information and Privacy Commissioner of Ontario, 2015) protocol are used and attached to the CNIH Privacy Policy (2017).
Principle 4 – Limiting collection
The collection of personal information and personal health information by CNIH is respected and collected for specific, limited and documented purposes.
Principle 5 – Limiting Use. Disclosure and Retention
Personal information or personal health information “shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by the law” (CNIH Privacy Policy, 2010).
CNIH is governed by the Private Career Colleges Act (2005) that requires the electronic storage of all college transcripts for 25 years, with a 3rd party.
CNIH uses personal information to provide services to administer student files (i.e. billing databases). From time to time, CNIH may contact alumni requesting additional personal information to assist us in maintaining our contact or mailing lists. We also collect personal information if a potential student sends an e-mail or phone call requesting information about our college and we use such information only for the specific purpose for which it was submitted.
CNIH does not disclose any personal information to any third parties, except as required by law, or in the case of an emergency.
The Canadian National Institute of Health Inc. promotes a culture where private information is safeguarded.
CNIH does not disclose any personal information to any third party to enable them to market their products and services.
There are pieces of legislation and regulations that must be followed e.g. the CDHO Records Regulation that states that client health records must be kept for 10 years after the last visit or in the case of a youngster, 10 years after they turn 18 years of age.
Principle 6 – Accuracy
The CNIH understands and supports that personal information must be accurate, complete, and updated for the purpose it was collected.
The CNIH recognizes the importance to create a culture where private information and private health information is safeguarded. In addition, the CNIH promotes a culture where personal information must be accurate, complete, routinely updated and maintained.
Principle 7 – Safeguards
The CNIH accepts the responsibility to protect personal information and personal health information with appropriate security safeguards.
Principle 8 – Openness
The CNIH will continue to make information readily available about our Privacy documents and practices relating to the management of private information and private health information.
Principle 9 – Individual Access
The CNIH will, upon request, give access to an individual’s private information and private health information and will assist in ensuring that the information is accurate. An individual has the right to examine their information and make corrections.
Principle 10 – Challenging Compliance
The CNIH promotes a culture where private information is safeguarded but understands that individuals may challenge the contents of this Privacy Policy.
An individual who has concerns with aspects of this Privacy Policy, or the conduct of a member of the CNIH organization has the opportunity to challenge the compliance, may make a complaint and communicate with the CNIH Privacy Officer; privacyofficer@cnih.ca
This document is evolving as the community we serve requires its growth.
Updated February 2018