Confidentiality

Policy

Category: Human Resources
Subject: Confidentiality
Division: N/A
Policy Number: Confidentiality
Effective Date: December 19, 2011

POLICY STATEMENT

Wellington-Dufferin-Guelph Public Health (WDGPH) policy sets out WDGPH’s commitment to and responsibilities for confidentiality.

All employees need to be aware of their responsibilities for confidentiality, safeguarding, and preserving information security. Consistent with these objective employees, service providers, agents, consultants, students, and volunteers must read and sign an Obligation of Confidentiality Agreement, as appropriate, prior to the commencement of their commitment to WDGPH.

Recognizing the sensitive nature of WDGPH’s services, it is important to protect WDGPH’s interests by ensuring trade secrets, confidential or proprietary information are not disclosed to anyone outside WDGPH, whether or not that person could benefit directly or indirectly from having that information, and that inventions (whether patentable or not) remain the property of WDGPH.

Collection, use and disclosure of confidential, personal or personal health information will be in accordance with Municipal Freedom of Information and Protection, (MFIPPA) and Personal Health Information Protection Act, (PHIPA).

Where appropriate, information that may be discarded in adherence with privacy and retention laws should be placed in special secured boxes provided for shredding purposes.

Employees’ Confidentiality

In order to properly administer the personnel functions we must gather and maintain confidential information of our employees. We take reasonable steps to ensure the accuracy, completeness, timeliness, and safeguarding of the confidential information in our possession.

WDGPH will not provide, unless required by law, access to an employee’s file to any third party without authorization from the employee, with the acceptance of Senior Management and Human Resources (HR) personnel as needed.

Employee’s confidential information will continue to be protected, as per retention laws after the termination of an employee.

Clients’ Confidentiality

Client’s confidential information should be safeguarded at all times and accessed only by employees involved in the delivery of service to the client. Client confidentiality must continue to be protected after the client’s discharge from the program.

Employees should not discuss mutual clients in common public areas in the workplace. Any discussions regarding clients should be conducted in a private area, away from others not involved in the case. Employees should take all reasonable precautions to prevent casual observation of client information by others. During transit, records will be kept in a carrying case, locked in a vehicle and kept out of sight within the vehicle where possible.  Records should not be kept in a vehicle for an extended period of time.

Employees must not release a client’s confidential information without proper consent (written or verbal), except when required by law. Employees must follow program based policies for collection, use and disclosure of confidential information, where applicable. Employees shall not give evidence or produce written records in court cases or coroners’ inquests unless required to do so by subpoena.

All requests for the release of confidential information from the police or a regulatory body must be directed to the Manager.

SCOPE

This policy applies to all employees, service providers, agents, consultants, students, volunteers and anyone else who may have access to technical, confidential or proprietary information of WDGPH.

RESPONSIBILITIES

Senior Management will:
  • Ensure all employees follow program and specific confidentiality policies, as applicable;
  • Ensure managers create, understand and follow policy guidelines regarding all confidential processes; and
  • Consult with appropriate personnel regarding confidentiality concerns or issues.
Managers will:
  • Ensure employees understand and adhere to this policy;
  • Ensure employees are oriented on program specific confidentiality;
  • Confirm that all ongoing audit and training for confidentiality is completed;
  • Provide and ensure employees, consultants, students, volunteers or any other individuals sign an Obligation to Confidentiality Agreement before given access to information covered by the Agreement; and
  • Ensure confidentiality is maintained within their program regarding clients, partners and employee information.
Employees will:
  • Understand and adhere to the policy;
  • Understand and sign a confidentiality obligation agreement;
  • Ensure confidentiality standards are maintained as required; and
  • Notify their Manager of any confidentiality issues immediately.
Human Resources will:
  • Provide and ensure all employees, consultants, volunteers, students and any other individuals sign an Obligation of Confidentiality Agreement as required;
  • Maintain complete confidentiality of all information of a confidential nature; and
  • Provide information regarding to confidentiality on any issues or concerns raised by management and/or employees.

DEFINITIONS

Confidential Information – means information in recorded or unrecorded form that is not generally available to the public and is generated, collected or used in the course of current and anticipated business activity including research and development activity. Confidential information does not need to be expressly marked as confidential.

Confidential Information Includes:

  • Personal, personal health, and sensitive information of WDGPH clients and other groups;
  • Information about a clients that is not available to the general public and is considered personal or sensitive, i.e. client lists, lists of suppliers, contracts;
  • Business and marketing plans, bids and proposals, surveys, plans and specifications purchasing and internal cost information, operating manuals, price and cost data, price and fee amounts, pricing and billing policies, quoting procedures, marketing techniques and methods, forecasts and forecast assumptions and volumes;
  • Employees’ personal information and information about the composition of work teams, as defined by MFIPPA, and personal health information, as defined by PHIPA; and
  • Identifying information that may be used for WDGPH research purposes, or for the development or continuous improvement of programs and services.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

Corresponding Procedure: N/A
CA.30.01.103  Obligation of Confidentiality – Service Provider/Consultant
CA.30.01.104  Obligation of Confidentiality – Employee
CA.30.01.105  Obligation of Confidentiality – Student/Volunteer
CA.52.01.101  Conflict of Interest
CA.52.01.121  Employee Personnel Files
CA.54.01.100  Voice Mail (draft pending approval)
CA.54.01.105  Computer Access and Usage (draft pending approval)
CA.58.01.101  MFIPPA
CA.58.01.102  PHIPA
CA.58.01.104  Access and Release of  Information
CA.59.01.100  Documentation Practices (draft pending approval)

APPROVED BY

Carole Desmeules