If you are using telemedicine or virtual health, you still need to provide a notice of collection of personal information.
The Advice to the Profession series from the College of Physicians and Surgeons of Alberta (CPSA) offers guidance documents to assist you in assessing the security risks and safeguards of electronic communications, such as telemedicine or virtual health.
From the College of Physicians and Surgeons of Alberta (CPSA):
Electronic Communications & Security of Mobile Devices
Along with helping you the assess the appropriate safeguards you need to take to protect the privacy and confidentiality of personal health information, the CPSA Advice also advises healthcare practices to ensure they have the consent of patients before providing virtual healthcare.
The collection notice is important to ensure the privacy rights of patients. But the notice is rather wordy to say before every virtual health encounter with your patients.
How can I ensure consent?
I've made it easier for you. I've recorded an audio file that you can download and save to your cell phone. Play the audio notice of collection at the start of each telephone or video call to properly inform the patient before the consult.
When you download the Practice Management Success Tip, Remote Working Privacy and Security Checklist, you will receive an email with a link to the audio file.
I hope that the checklist and the audio file will help you to make good business decisions and, if this is the right fit for you, help you to provide virtual health to your patients.
You can use the collection notice below to prompt the clinician to ask the individual for their name and date of birth at the outset of the call.
If you are using a video conference call, you could also consider having the patient display their photo ID to the camera.
Remember – don't use the record feature for the video conference call!
The clinician then documents in the patient's chart that the patient's identity was verified by having the patient verbally provides their name, date of birth (and/or photo ID).
Script – Notice Of Collection
Unregulated virtual care technologies increase the risk that your personal health information may be intercepted or disclosed to third parties. These tools are being used as an extraordinary measure during the COVID-19 pandemic when regulated technology is not readily available, and the necessity to keep people from congregating or attending health facilities where they may be exposed to the COVID-19 virus is thought to outweigh the risk of personal privacy breaches on both a personal and population health basis.
By providing your information, during this teleconference or video conference call, you agree to let us collect, use, or disclose your personal health information through video or audio communications in order to provide you with care.
You will be asked to state your full name and date of birth will confirm your identity and ensure accurate record keeping.
Continuing with this telephone or video conference call indicates your consent to the collection of your personal information as authorized under the Health Information Act of Alberta.
And get the Collection Notice audio for FREE.
The Practice Management Success Tip, Remote Worker Privacy and Security Checklist, will help you
- Determine if remote working is appropriate for your employees.
- Identify what clinic / business resources need to be provided to the employee remote worker.
- What reasonable safeguards need to be implemented to protect the privacy, confidentiality, and security of personal (health) information.
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