Electronic Health Record Description and List of Repositories

The Personal Health Information Protection Act, 2004 (“the Act”) is a privacy law which primarily governs the collection, use and disclosure of personal health information and sets requirements for persons and organizations who manage personal health information to protect individuals’ privacy and their rights. The Act permits organizations to be prescribed so that they can collect, use or disclose personal health information for specific purposes. Ontario Health is prescribed as the organization which develops and maintains the electronic health record, (“the Prescribed Organization”) in accordance with Part V.1 of the Act and its associated regulation (Ontario Regulation 329/04).

The electronic health record contains a secure digital record of individuals’ personal health information contributed by authorized health information custodians. It is updated in near real time and available electronically to authorized health information custodians so that they can quickly collect, use, and disclose critical personal health information, thereby improving quality of care. Examples of health information custodians include: health care practitioners (including physicians, nurses), hospitals, long-term care homes, retirement homes, pharmacies, laboratories, ambulance services, medical officers of health of boards of health and the Minister of Health.

As a prescribed organization in respect of the development and maintenance of the provincial Electronic Health Record, Ontario Health:

• Manages and integrates the personal health information it receives from health information custodians;
• Ensures the proper functioning of the electronic health record;
• Ensures the accuracy and quality of the personal health information in the electronic health record;
• Conducts analyses of the personal health information in the electronic health record in order to provide alerts and reminders to health information custodians for their use in the provision of health care; and
• Carries out other powers, duties or functions as prescribed.

In general, health information custodians will only be permitted to access the electronic health record to provide or assist in the provision of health care to an individual or if the health information custodian has reasonable grounds to believe it is necessary to eliminate or reduce a significant risk of harm to a person or group of persons.

Ontario Health may also provide personal health information that is held within the electronic health record to a coroner, the Chief Medical Officer of Health (CMOH), or a medical officer of health for purposes related to their duties under applicable laws. The Minister of Health may also direct Ontario Health as the Prescribed Organization to disclose personal health information for specified purposes, such as research, and Ontario Health must do so in accordance with the conditions of the Act. Ontario Health also supports individuals who seek access or wish to make a consent directive in respect to their records of personal health information held in the electronic health record.

Descriptions of types of personal health information (PHI) received

The electronic health record consists of the following repositories which contain personal health information received by health information custodians pursuant to the Act and its regulations.

Acute and Community Clinical Data Repository (acCDR)

Description of PHI: Acute and community care clinical information

Type of PHI: Patient demographics, emergency Department reports, consultation reports, discharge summaries, cardiovascular results, mental health reports, as well as home and community care records including long-term care placement details, risk assessments, and care plans.

Source: Hospitals and home and community care organizations

Diagnostic Imaging- Common Service (DI- CS)

Description of PHI: Diagnostic imaging information

Type of PHI: Diagnostic imaging reports and image manifests for X-ray, CT scan, MRI, ultrasound, and others.

Source: Hospitals and integrated community health service centres

Digital Health Drug Repository (DHDR)*

Description of PHI: Medication and pharmacy service information

Type of PHI: Records of medications prepared and pharmacy services provided at community pharmacies and medications administered at hospitals.

Source: Ministry of Health, community pharmacies, and hospitals

Ontario Laboratories Information System (OLIS)

Description of PHI: Laboratory information

Type of PHI: Laboratory test orders and results for biochemistry, hematology, pathology, blood bank, microbiology, and genetics testing.

Source: Ministry of Health, hospitals, community labs, and public health labs

Provincial Client Registry (PCR)

Description of PHI: Patient demographics and identity information

Type of PHI: Health card numbers, medical record numbers, name, date of birth, address information, and other identifiers.

Source: Ministry of Health, acute care hospitals, community care, and participating health care organizations

Primary Care Clinical Data Repository (pcCDR)*

Description of PHI: Pilot Project Clinical information submitted via certified electronic medical record systems

Type of PHI: Patient demographics, medications, allergies, adverse reactions, current health conditions, past medical and surgical history, immunizations, risk factors, vitals and vitals trends.

Source: Primary care providers such as general practitioners or family physicians

*Some PHI within this repository may not be accessible by means of the electronic health record

Overview of administrative, technical and physical safeguards

For information about Ontario Health’s information practices related to the electronic health record, visit the Prescribed Organization Statement of Information Practices.

For information about Ontario Health’s safeguards, visit Safeguards for the Protection of Personal Information and Personal Health Information.

Ontario Health has implemented administrative, technical and physical safeguards specific to the electronic health record to:

• Protect against theft, loss and unauthorized collection, use or disclosure of the personal health information accessible by means of the electronic health record;
• Protect the personal health information accessible by means of the electronic health record against unauthorized copying, modification or disposal; and
• Protect the integrity, security and confidentiality of the personal health information accessible by means of the electronic health record.

Physical Safeguards

• Access to office areas where business processes require access to PI or PHI is physically restricted to only employees and other Ontario Health agents whose role involves handling of PI or PHI. Other staff members do not have physical or logical access to those areas.
• Decommissioned equipment that was used to process or store PI or PHI is securely disposed of, according to approved procedures.
• Procedures and appropriate equipment are in place for secure disposal of physical or digital media that may have sensitive information.

Administrative Safeguards

• Any third party we retain to assist in providing services to Ontario Health or to health information custodians will have formal contracts and service level agreements, with the restrictions and conditions to protect Ontario Health information.
• Ontario Health employees, agents and clients must promptly report any privacy and security breaches for investigation. Privacy and Security Incident Management Policies and Procedures are in place to ensure management of incidents and regular training and awareness for staff members involved in incident management.
• We provide a written copy of the summary of results of privacy impact assessments and security threat and risk assessments to the affected health information custodians.
• Administrator and operator logs, logs recording user activities, exceptions and Information security events are logged and kept online for 1 year and offline for a minimum of 1 year or as otherwise directed through a Data Retention/Destruction Policy/Standard for logs containing PHI/PI information.
• Log files beyond the retention or archival requirements are securely destroyed using approved methods.
• We keep an electronic record of each and every access to personal health information to identify who accessed the information and on what date, in case of incidents.
• Log data required for litigation support are kept until the disposition of the legal matter.

Technical Safeguards

• Strong authentication solutions are required for access to sensitive information.
• Administrative access to Ontario Health IT equipment and applications is provided on a need-to-know basis controlled via proper authorization and strong, two-factor authentication. All system and application access activities are logged.
• Network traffic is managed and monitored using security mechanisms such as routers, switches, network firewalls, intrusion detection systems, and anti-virus programs.
• All sensitive data is encrypted in traffic between external sources and Ontario Health systems.
• All data stored on staff computers is encrypted.
• Data integrity controls are implemented as a quality assurance activity on the personal health information provided to us by health information custodians. Data integrity controls are also used to prevent the unauthorized modification and destruction of this data.
• Independent vulnerability assessments of technical configurations and operational security practices are conducted periodically.
• A patch management process is in place to ensure that operating systems, databases and applications receive security patches and functional updates in a timely manner.
• Upon termination of employment or contracts, all accounts of former staff or consultants are deleted and access is disabled.
• Data and applications are backed up on a regular basis and can be easily restored in case of operational incidents.
• Logging, monitoring and auditing system record when PI and PHI are accessed or transferred.
• Comprehensive disaster recovery and business continuity plans are tested and updated as needed on a regular basis.