External Requests for WDGPH Data

Policy

Category: Health Analytics
Subject: External Requests for WDGPH Data
Policy Number: CA.41.01.103
Effective Date: August 31, 2011

POLICY STATEMENT

The purpose of this policy is to establish a process to ensure fair and reasonable access to data while preserving the integrity and confidentiality of data collected by Wellington-Dufferin-Guelph Public Health (WDGPH).   

DEFINITIONS

The Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans (TCPS) is a joint policy of Canada’s three federal research agencies – the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council of Canada (NSERC), and the Social Sciences and Humanities Research Council of Canada (SSHRC), or “the Agencies.” This Policy expresses the Agencies’ continuing commitment to the people of Canada to promote the ethical conduct of research involving humans. It has been informed, in part, by leading international ethics norms, all of which may help, in some measure, to guide Canadian researchers, in Canada and abroad, in the conduct of research involving humans.

Aggregate Level Data: Data about groups of individuals. The data is aggregated in such a manner as to prevent the identification of individuals.

Person-Level Data: Data is provided about individuals but the identifiers have been removed or encrypted.

Person-Identifiable Data: Data that includes personal information that permits the identification of individuals, for example name, date of birth, address, postal code, health card number.

Confidentiality and Security of Data

WDGPH places the highest importance on the protection of confidentiality and security of the data housed in WDGPH databases.  The policies and procedures for accessing WDGPH data were developed in accordance with Ontario’s Personal Health Information Protection Act (PHIPA), the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and the WDGPH Privacy policies CA.58.01.101MFIPPA, and CA.58.01.102 PHIPA.

WDGPH Data Access Request Review Criteria

WDGPH will assess the applicant’s proposed intent for the use of the data and application of the knowledge. WDGPH will use the following criteria to evaluate the application:

  • Consistency of the purpose for which the data will be used with the requirements and outcomes of the Ontario Public Health Standards;
  • Consistency of the purpose for which the data will be used with the mission, vision, values, strategic directions and identified priorities of WDGPH;
  • The appropriateness and specificity of the data requested to the research project and methodology (the data analysis methodology must be sufficiently detailed to allow for assessment); and
  • Capacity of WDGPH employees to extract and prepare the data (time and effort required).

Principles Respecting Access to Data

  • WDGPH will only release aggregate level data; WDGPH will not release person level data or person-identifiable data;  
  • Applicants will be required to submit a written request to access WDGPH data as described in procedure CA.41.02.103 External Requests for WDGPH Data; 
  • Conditions respecting access to data are listed in the procedure CA.41.02.103 External Requests for WDGPH Data; and
  • If the application is approved, researchers will be required to sign a contractual agreement with WDGPH.

Ethics Review

All applications for access to WDGPH data that are requested for the purpose of research involving humans, as defined by the Tri-Council Policy Statement, must receive approval from the Ontario Agency for Health Protection and Promotion (OAHPP) Ethics Board.  WDGPH reserves the right to refer a data request to the OAHPP Ethics Board for an opinion regarding whether the project constitutes research involving humans.

There may be circumstances where the request for data does not require Research Ethics Board approval as in the case where ethics approval from another Ethics Committee has been received. Applicants should include the findings of the Ethics Committee with their application and this information may be subject to review by the OAHPP Research Ethics Board. 

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

CA.41.02.103 External Requests for WDGPH Data
CA.58.01.101  MFIPPA
CA.58.01.102  PHIPA
Ontario’s Personal Health Information Protection Act (PHIPA)
Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)

 

APPROVED BY

Andrea Roberts  


Procedure

Category: Health Analytics
Subject: External Requests for WDGPH Data
Procedure Number: CA.41.02.103
Effective Date: August 31, 2011

PROCEDURE

Applicants will be required to submit a written request to access Wellington-Dufferin-Guelph Public Health (WDGPH) data (see CA.30.01.950 Application Form for Access to Data).  

Applicants will be encouraged to contact WDGPH and discuss the data request prior to completing the application form. 

Conditions Respecting Access to Data

The following conditions will apply when a researcher is granted access to WDGPH data:

  • Only the minimum data required to fulfill the purpose outlined by the applicant in the Application Form will be considered for release.
  • Data must be used only for the purposes for which it was requested and may not be transferred to other parties without advance approval in writing from WDGPH.  
  • Data files shall be returned to WDGPH when no longer required for the purpose for which they were made available, and any copies of the data shall be destroyed.  The applicant will be required to certify in writing that this has been done.  
  • The applicant must provide WDGPH with the identities of all individuals who will have access to the data.  Employees or anyone who will have access to WDGPH data will be required to sign a CA.30.01.951 Obligation of Confidentiality form for Service Providers and Agents/Consultants.   
  • In cases where it is deemed appropriate, the knowledge and consent of the clients in the data may be required prior to the release of the information.
  • All applicants who are requesting the release of data to be transferred to another computer will be required to sign a contractual agreement.

REFERENCES AND RELATED FORMS, POLICIES AND PROCEDURES

CA.41.01.103   External Requests for WDGPH Data
CA.30.01.950  Application Form for Access to Data
CA.30.01.951  Obligation of Confidentiality Form for Service Providers and Agents/Consultants

APPROVED BY

Andrea Roberts