Confidential Interviewing of Clients

Policy

Category: Control of Infectious Diseases
Subject: Confidential Interviewing of Clients
Division: Health Protection
Policy Number: CA.86.01.110
Effective Date: October 1, 2015

POLICY STATEMENT

Employees of the Health Protection Division (HPD), acting in the capacity of Wellington-Dufferin-Guelph Public Health (WDGPH), is responsible for protecting clients’ confidential and personal health information from unauthorized disclosure internally and externally. The purpose of this policy is to establish the terms and conditions of conducting a confidential interview which respects the privacy and confidentiality of clients at all times. The policy is based on professional guidelines, best practice, and applicable legislation (PHIPA). It is designed to help staff understand their legal and professional obligations to maintain client confidentiality during an interview.

The HPD acknowledges and respects the privacy of individuals, families, groups, and facilities. Accordingly, HPD employees will collect information with the client’s knowledge and consent. The information collected will be used for the purpose it was collected and information will not be disclosed to a third party without the client’s consent except if it is required by law.

SCOPE

This policy applies to all HPD employees, students, and volunteers who conduct interviews as part of disease follow-up or an investigation, or have access to confidential information.

DEFINITIONS

Personal Health Information – Any personal information about an individual collected in oral or written form.

Identifying Information – Any information that identifies an individual or any information where it is reasonably foreseeable that it could be used with other information to identify an individual.

Consent – Authorization by an individual or client to process personal or identifying information based on their informed understanding of what WDGPH intends to do with the collected information.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Procedure CA.86.02.110 Confidential Interviewing of Clients
CA.50.01.101 and CA.50.02.101 Documentation Practices
CA.52.01.126 Confidentiality
CA.58.01.100 and CA.58.02.100 Privacy Governance
CA.58.01.101 MFIPPA
CA.58.01.102 PHIPA
CA.58.02.103 Privacy Breach Protocol
CA.58.02.104 Access and Release of Information
Confidentiality and Privacy: Personal Health Information (Practice Standard, College of Nurses of Ontario)
Consent (Practice Guideline, College of Nurses of Ontario)

CONTACT FOR INQUIRIES

Manager, Control of Infectious Diseases and Tuberculosis

APPROVED BY

Director, Health Protection 


Procedure

Category: Control of Infectious Diseases
Subject: Confidential Interviewing of Clients
Division: Health Protection
Procedure Number: CA.86.02.110
Effective Date: October 1, 2015

PROCEDURE

Interviewing a client is an important step in collecting information essential for formulating a hypothesis about disease transmission or determining the source of an outbreak. A confidential client interview must be considered in two parts:

The Procedure:

Employees will introduce themselves stating name, role, and purpose of the interview (clarification of why you are asking the questions). Employees will also ensure client readiness, privacy, and comfort, and indicate the estimated time required for the interview/questions. Employees must address terms of confidentiality, invite client questions, and advise the client that rough notes may be taken during the interview but will be transcribed into the official electronic record of the investigation and then shredded.

The Setting:

Consideration of the setting where the interview is conducted is important for ensuring client confidentiality. Employees should make the interview setting as private and comfortable as possible. It is the employee’s responsibility to make adjustments to the setting to ensure privacy. The privacy of the setting and/or environment will greatly influence the client’s comfort in answering questions. Always ask for the client’s permission before beginning an interview with another person present even if it is a family member, spouse, or friend.

RESPONSIBILITIES

Management will:
  • Implement and review confidentiality and privacy policies annually to ensure policies reflect the current legislation;
  • Investigate all complaints and report all known privacy breaches to the organization’s privacy officer; and
  • Orient new employees to all privacy and confidentiality policies during their orientation and have them sign a confidentiality agreement.
Employees will:
  • Comply with organizational and divisional policies on confidentiality and privacy legislation when conducting a client interview, investigation, or site inspection;
  • Inform clients about confidentiality before interviewing and collecting personal health information;
  • Inform clients of the purpose of the interview and how information collected may be used; and
  • Obtain expressed or written consent from the client before disclosing any personal health information or identifying information to a third party.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Policy CA.86.01.110 Confidential Interviewing of Clients
CA.50.01.101 and CA.50.02.101 Documentation Practices
CA.52.01.126 Confidentiality
CA.58.01.100 and CA.58.02.100 Privacy Governance
CA.58.01.101 MFIPPA
CA.58.01.102 PHIPA
CA.58.02.103 Privacy Breach Protocol
CA.58.02.104 Access and Release of Information
Confidentiality and Privacy: Personal Health Information (Practice Standard, College of Nurses of Ontario)
Consent (Practice Guideline, College of Nurses of Ontario)

CONTACT FOR INQUIRIES

Manager, Control of Infectious Diseases and Tuberculosis 

APPROVED BY

Director, Health Protection