Information Managers
  • Home
  • Services
    • All Services
  • Templates
  • Blog
  • Contact Us
  • Practice Management Success
  • Podcasts

3 Parts to Every Privacy Awareness Training Plan

Posted on June 15, 2020 by Jean Eaton in Blog, Clinic Manager / Privacy Officer, Employee, Established Practice, New Practice, Services

Reasonable Safeguards – the Myth

You may have heard the myth that the Health Information Act (HIA) is a big scary thing that will interrupt your routine, rob you of countless billable hours, impact all of your staff, turn your office inside out, and change the way that you run your entire business!

Myth Buster

The HIA provides structure and framework for reasonable safeguards that apply to any healthcare business.

One of the requirements of reasonable safeguards includes having a privacy awareness training plan.

     
Privacy Awareness Training

Click the >> arrow to play the video

Privacy Awareness Training

Your Privacy Awareness Training Plan should include learning objectives throughout the year, including

  • Orientation – Standardized training curriculum provided to everyone in you healthcare practice at the time of employment. This is often included during a new employee’s orientation period.
  • Specific – Privacy training that is more detailed and specific to the roles and responsibilities of that individual’s job in your healthcare practice. There may also be specific training when new software, technology, or procedures are introduced anytime throughout the employment.
  • Reward – Keep privacy awareness top of mind all year long. Recognize and reward when individuals follow privacy principles that also add value to your client satisfaction or business efficiency.

It is reasonable to expect regular privacy awareness training, especially at orientation, and a formal review annually.

What a Privacy Awareness Training Plan Can Do For You

When you implement regular privacy awareness training, you will see:

  • Privacy and security expectations clearly communicated among your team.
  • Team members demonstrate their commitment to privacy, confidentiality, security of personal health information.
  • Efficient practices that protect the privacy and save you time and money
  • Team members confidently and correctly handle personal health information using reasonable safeguards

Are You a Myth-Buster?

You can be a myth-buster, too, and implement privacy awareness training in your healthcare practice.

You can easily implement reasonable safeguards and meet HIA requirements to ensure privacy, confidentiality, and security of health information that saves you time, frustration and money.

If you need a little help, I have written a practical privacy awareness training course designed for the community health care practice. This is ideal for orientation of new employees and a refresher for the rest of us.

Privacy Awareness in Healthcare: Essentials

Understand basic health care privacy principles and how to handle personal information, use safeguards, and recognize and report a privacy breach.

Ideal for community-based health care professionals and staff, direct care providers, or anyone working with a health care, dental, or social services organization.

An effective privacy compliance program promotes organizational adherence to the Health Information Act (HIA), Personal Information Protection Act (PIPA) Alberta, Personal Health Information Protection Act (PHIPA) Ontario and the Personal Information Protection of Electronic Documents Act (PIPEDA) requirements. A compliance program is your first line of defense to promote the prevention of criminal conduct, and enforce government rules and regulations, while providing quality care to patients. All three training products help protect practices against privacy and security breaches, improper payments, fraud and abuse, and other potential liability areas through education.

Canadian Health Care Privacy Training Solutions

Corridor’s online training makes it easy for health care organizations to comply with provincial and federal legislation that mandates regular privacy training for all health care providers, staff, and vendors.

Select the training that best fits your needs:

NEW! Privacy Awareness in Healthcare Training: Dental Practices – Alberta

Dentists and dental practices in Alberta are required to have an ongoing privacy program to ensure the protection of private records and patient information. The appropriate collection, use, and disclosure of personal information is critical to maintaining privacy for patients that choose to trust in your practice. Accomplishing this important goal demands an up-to-date training strategy.

Privacy Awareness in Health Care Training – Canada

Includes detailed resources for each province and territory with key terminology and links to applicable privacy legislation. Resources are provided for our ten provinces: Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland & Labrador, Nova Scotia, Ontario, Prince Edward Island, Quebec, Saskatchewan, and three territories: Northwest Territories, Nunavut and Yukon. This new product is ideal for both organizations and vendors who provide health care services or have health care clients in more than one province.

Privacy Awareness in Health Care Training – Alberta 

Includes the mandatory privacy breach notification amendments to the Health Information Act (HIA).

Privacy Awareness in Health Care Training – Ontario

Specifically covers all legislation and rules specific to the province of Ontario including the Personal Health Information Protection Act (PHIPA).

Refresher: Privacy Awareness in Health Care – Alberta

A quiz-based review of Corridor’s full Privacy Awareness course. The Refresher starts with an initial quiz to assess knowledge on the topics and information covered in the full course. Based on the quiz results, one or more of eight Refresher topic quizzes must be completed, each focusing on a specific subject area. The Refresher also includes access to the original course content.

 

Privacy Awareness in Healthcare: Essentials

Grab your on-line course from Information Managers and Corridor Interactive

for just $30 per individual 3 month subscription now!

Click Here to Grab Your On-Line Privacy Awareness Course Now!
Alberta, Canada, Corridor Interactive, dental, Health Information Act, Ontario, Personal Health Information Protection Act (PHIPA), PHIPA, PIPEDA, privacy awareness training, reasonable safeguards

PIPEDA Mandatory Privacy Breach Notification

Posted on January 19, 2020 by Jean Eaton in Blog

Organizations subject to PIPEDA are required to report to the OPC any breaches of security safeguards involving personal information that pose a risk of significant harm to the individuals.

PIPEDA

PIPEDA is a Canadian federal law that sets out the rules for the collection, use and disclosure of personal information in the course of those commercial activities. PIPEDA outlines the 10 Fair Information Privacy Principles that businesses must follow regardless of their size. Organizations need to know privacy rules and make sure that you have the appropriate safeguards implemented in your business.

 

Does PIPEDA Apply To You?

image of map of Canada

PIPEDA applies to most businesses across Canada, excepting Quebec, British Columbia, and Alberta. These provinces have their own private sector laws that are substantially similar to PIPEDA.

But even in those provinces, PIPEDA covers federally regulated industries like transportation, telecommunications and banking. In addition, all businesses that operate in Canada and handles personal information that crosses provincial or national borders are subject to PIPEDA, regardless of which province or territory that they're based in. All businesses in the three territories also fall under PIPEDA.

In Alberta, we have privacy legislation called the Health Information Act (HIA) that takes precedence over PIPEDA and Alberta's Personal Information Protection Act, (PIPA). If a business, like a physician's office, has a privacy breach which includes health information, then the custodian of the physician office must report the privacy breach following the HIA regulations. If employee information or other non-health information is included in the breach then that triggers privacy breach notification under PIPA. Sometimes, a breach can include both types of information and the physician office must notify under each legislation.

In BC, the Personal Information Protection Act (PIPA) is BC's private sector privacy law that has also been deemed substantially similar to the federal private sector privacy law. BC does not have health information specific privacy legislation, so PIPA applies to private organizations in BC, including physician practices, and governs how the personal information about patients, employees and volunteers may be collected, used and disclosed.

If you are a business in Canada, for example, an electronic medical records (EMR) business and you have a data center in Canada where all of your clients across Canada provide their information and store it in your data center, the EMR vendor likely falls under the PIPEDA regulations.

The vendor may be responsive to other legislation as well. If you are an EMR vendor, you do not directly comply with the HIA in Alberta because that applies only to custodians. However, as an information manager of a custodian under the HIA, you have some obligations under the HIA in the event of a privacy breach. But that does not mean that you don't also have obligations under PIPEDA.

 

What Is Included In Personal Information?

image file folders

Personal information is more than just a name or an address. It's data about an identifiable individual that can, by itself or combined with other information, identify a person. It could be a person's age, ethnicity, medical information, credit card number or even an income level. It might also include their Internet Protocol (IP) address or their website or email information.

Regular surveys done by the Office of the Privacy Commissioner of Canada says that small businesses tend to be less aware of their privacy responsibilities than larger organizations. In 2017, 65% of large organizations with more than 100 employees indicated that they were privacy aware. But only 43% of small businesses indicated that they were privacy aware. Smaller companies may not have dedicated compliance officers or privacy officers, and they may not have a sense of privacy knowledge.

The compliance challenge for smaller organizations is made more difficult by the limited human and sometimes the financial resources available to them and the gap on the knowledge about the privacy obligations.

Lack of awareness can potentially lead to complaints about your business, which has an impact on your business's reputation.

 

Privacy Breach

A privacy breach occurs when there is an unauthorized access to or the collection, use, disclosure, our disposal of personal information. There are many things that could qualify as a privacy breach. If you have a financial transaction that includes clients’ information and now is publicly available on your website, that's a privacy breach. If you have somebody in your organization who has access to personally identifying information as part of their job, but they use it for some purpose other than their job, that's snooping, and that is a privacy breach.

There are many examples about what is a privacy breach, but any time that you view, use, or disclose without aauthorization is considered a privacy breach.

Privacy breaches also have a negative impact to our business because it takes time and resources to manage a privacy breach, and it has a huge impact to the reputation of an organization.

 

Privacy Breach Notification

image timeline

The November 2018 PIPEDA mandatory privacy breach notification regulations requires you to know where all of your personally identifiable information sources are and know the safeguards implemented to protect the data.

Then, you need to monitor the data to identify any breaches. If there is a breach of those security safeguards, you need to record all breaches. So even if there is a breach of a safeguard that nobody has exploited, you still need to record that you have identified that there is a potential risk and what you've done to be able to manage that risk and prevent that from happening again.

Next, you need to determine the risk of significant harm, or ROSH. (more about this later.)

The risk of harm test that identifies what information had been included in the breach and the type of harm that could happen to that individual as a result of the breach. When it reaches that ROSH threshold, then you need to notify the Office of the Privacy Commissioner of Canada office. Or, if you are in BC, Alberta or Quebec, you need to report that to the provincial privacy commissioner.

You also need to notify other people about that privacy breach.

You probably need to notify your clients. If you are an EMR vendor or another vendor that's providing a service to healthcare providers, you need to notify them about the breach.

As an example, if you are an EMR vendor that has been breached–perhaps a security compromise or hack into your data centre–you have a responsibility to notify the healthcare providers who collected the personal information. The EMR vendor must also report the privacy breach to the Office of the Privacy Commissioner.

You might also have an obligation to notify the individuals that have been affected by that breach. In your information manager agreement in Alberta, you should have clear written expectations about whether or not a vendor should notify the patients directly about a privacy breach or if the custodian or the health care provider is going to assume that responsibility. This is an important detail that you need to identify in your information manager agreement.

Also see the Practice Management Success Tip Top 3 Agreements Your Healthcare Practice Must Have (And Why) from Information Managers at https://InformationManagers.ca/top-3 for more on information management agreements (IMA.)

 

ROSH

image lady with paper

The risk of significant harm (ROSH) is a framework for assessing the risk to the individual as a result of the breach of individually identifying information. Adopt and use a framework for your organization to assist you to quickly and consistently assess a breach for ROSH.

If there is personally identifying information included in the breach, we can assume that the information is sensitive information to the individual. Generally, I recommend a default that if individually identifiable information is included in the breach, then assess that there is a significant risk of harm to the individual.

The circumstances of a breach may make the information more or less likely to be used maliciously. For example, additional questions that you may want to consider include how did the breach occur? How likely is it that someone would be harmed by the breach? Who actually accessed or could have accessed that personal information? How long has that personal information been exposed? Is there evidence of malicious intent, like hacking? Or was it a theft? Or did somebody intentionally tried to use that information and use it in a very covert way? Were a number of pieces of personal information breached therefore, increasing the risk of misuse? Is the breached information in the hands of an individual that represents a reputation to the risk of that individual or themselves? Or, was the information exposed to a limited, known number of entities who have committed to destroy and not disclosed the data.

 

Privacy Is Good For Business

image people in business

As always, good privacy is good for business. Poor privacy protection can damage your company's reputation and cut into your profit margin. When your practice proactive privacy, you enjoy the confidence and trust of your customers. Canadians tell us that the more they trust a company, the more likely they are to do business with it. Getting privacy right is your opportunity to demonstrate that you deserve their trust and their business.

Remember that one of the fair information principles is accountability. At the end of the day, you are responsible for protecting the personal information that you have collected.

 

Reference: Privacy and your business: An introduction to the Personal Information Protection and Electronic Documents Act. Office of the Privacy Commissioner of Canada. https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/pipeda-compliance-help/pipeda-compliance-and-training-tools/pp_bus/

Privacy Management Program

Build privacy protections into everything you do is a business. Having clear policies and procedures for the collection, use and disclosure of personal information is of vital importance for your business.

 

When we know better, we can do better…

I’ve helped hundreds of healthcare practices prevent privacy breach pain like this. If you would like to discuss how I can help your practice, just send me an email. I am here to help you protect your practice.

How to Manage a Privacy Breach with Confidence

The 4 Step Response Plan will help you with prevent privacy breach pain and give you the tips, templates, training, and tools that you can use right away to prepare your privacy breach response plan:

In the world of privacy breaches ‘If’ has become ‘When’. Will you be ready?

The best way to do this is by developing a privacy management program that covers all aspects of how you handle personal information. The 4 Step Response Plan will help your organization be prepared to prevent privacy breach pain. 

Click here for more information on the on-line 4 Step Response Plan course available now!

image

 

 

Learn How To Manage A Privacy Breach With Confidence
#PracticeManagementNugget, Canada, healthcare, mandatory notification, mandatory privacy breach notification, personal information protection electronic documents act, PIPEDA, podcast, privacy breach

New Mandatory Privacy Breach Notification Form

Posted on September 13, 2018 by Jean Eaton in Blog

AS of August 31, 2018, the new Alberta regulations regarding mandatory privacy breach notification requirements are in force.

The Alberta Minister of Health (MOH) and the Office of the Information and Privacy Commissioner (OIPC) have published the mandatory notification forms for you to submit your privacy breach notifications.

You can download the forms here:

Notification to Alberta’s Minister of Health: http://www.health.alberta.ca/about/Health-Information-Act.html

Notification to the OIPC: https://www.oipc.ab.ca/forms.aspx

You Will Be FINED $50,000 if You Don't Do This!

If you don’t have an active privacy breach management program and are not compliant with mandatory privacy breach notification, you may be fined up to $50,000.

I recommend that you also use an internal privacy breach reporting form to document your investigation and reporting. The form will help you to navigate the privacy breach management process and record information for your internal use. You can then copy and paste the necessary information to the mandatory notification forms.

If you are a member of Practice Management Success, login and access the Procedure Privacy Breach Management Template including the Privacy Breach Report Form.

Not a member of Practice Management Success, yet?

What are you waiting for?

Get Your Practice Management Success membership

If you are a member of the 4 Step Response Plan, login and access my video and review of how to use the MOH and the OIPC forms.

What You Should Do Now

  1. Update your current privacy breach reporting policies and procedures with the new requirements for mandatory privacy breach notification.
  2. Include copies of these new forms in your procedures so that you can easily access them when needed.
  3. Ensure that your custodians are aware of the new mandatory privacy beach notification regulations. You can share the e-book, Understanding Privacy Breach Notification, to assist you.

Additional Resources

Alberta Health has also added a new chapter, Duty to Notify, to their HIA Guidelines Manual. You can download this chapter here. This provides additional examples of privacy breaches and appropriate responses including comments from OIPC investigations.

 When we know better, we can do better…

Jean L. Eaton is constructively obsessive about privacy, confidentiality, and security especially when it comes to the handling of personal health information. If you would like to discuss how I can help your practice, just send me an email. I am here to help you.

Jean L. Eaton
Your Practical Privacy Coach
INFORMATION MANAGERS

Alberta, Canada, health care, healthcare, mandatory breach notification, mandatory privacy breach notification, medical, Practice Management Success

How to Turn Your Hectic Waiting Room Into a Reception Area!

Posted on November 22, 2017 by Jean Eaton in Blog, PMN Replay

Are you a clinic manager who dreads the Monday morning phone rush?

Are your walk-in patients pushy, impatient, and frustrated waiting for their turn to see the doctor?

Do your patients complain about how difficult it is to phone into the clinic just to make an appointment?

You can do better than that!

My guests on Practice Management Nuggets Webinars for Your Healthcare Practice will show you how!

Chris Naraine, National Sales Director and Robert Cove, Solutions Consultant of Bleen know how automated scheduling solutions can help your small to medium family medical practice

  • Reduce 40% to 60% of your incoming phone calls.
  • Reduce 75% of your no-show appointments.

If you are ready to change your hectic, stressful front office for an efficient, respectful front office and you are a

  • Clinic manager of a small to medium family healthcare practice or
  • Healthcare provider planning a new practice

Jump on this FREE Interview with automated scheduling solutions experts Chris Naraine and Robert Cove and discover how you can improve your patient flow management.

Make an appointment with your family physician on the first attempt, no waiting, when convenient for you.

Are you ready for

  • Timely access and less waiting
  • Canadian automated scheduling solution
  • On-line booking, appointment reminders
  • Reduce no shows and rapidly fill cancellations
     

Click Here to Register for the Free Webinar

Register for the Free 30 minute webinar! Replay available for a limited time.

 Check Out this Interview NOW to Get Started!

Do You Want to Turn Your Hectic Waiting Room Into a Reception Area?

with Chris Naraine, National Sales Director and

Robert Cove, Solutions Consultant of Bleen

Live Thursday November 23, 2017

Register for the Free Webinar

Along with your registration for the event you'll also benefit from weekly email reminders of the next guest expert on Practice Management Nuggets Webinars for Your Healthcare Practice.


Practice Management Nuggets Webinars

The perfect lunch break for busy practice managers – only 30 minutes and it’s free!

Practice Management Nuggets Webinars is a regular interview series with practice managers, healthcare providers, or trusted vendors who support healthcare practices. Topics include things you need to know to help you start, grow, fix, or maintain your healthcare practice. The events will be short – about 30 minutes – with nuggets of information that you can use right away.

And best of all – this is a free, no cost opportunity for you and your staff to hear from experts on a variety of topics how they made their clinics and businesses a success! Register now to receive a weekly update of the Practice Management Nugget Webinar guest speaker. Even if you can’t attend register anyway and we will send you the replay. Replays will be available for only a limited time.

Practice Management Nuggets’© series is hosted by Jean L. Eaton, Your Practice Management Mentor of Information Managers Ltd.

 

#digitalhealth, #PracticeManagementNuggets, automated scheduling solution, Bleen, Canada, health care, healthcare, medical, on-line booking, practice management

Search the site

What is the elephant in the room?

The Elephant in the Room Find out here...

Privacy Policy

I have used Corridor's Privacy Awareness in Healthcare: Essentials online training program. The course has helped satisfy the training requirements of the Health Information Act. Staff go through the course at their own pace while we monitor to ensure completion.

- Luke Brimmage, Executive Director, Aspen Primary Care Network

Register for Free On-line Privacy Breach Awareness Training!

Privacy Policy

Copyright 2022 Information Managers Ltd.

Manage Cookie Consent
To provide the best experiences, we use technologies like cookies to store and/or access device information. Consenting to these technologies will allow us to process data such as browsing behavior or unique IDs on this site. Not consenting or withdrawing consent, may adversely affect certain features and functions.
Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
Manage options Manage services Manage vendors Read more about these purposes
View preferences
{title} {title} {title}