PREPARED BY:
Planning and Strategic Initiatives
DATE:
March 21, 2024
SUBJECT:
2023 Privacy Summary Report
BACKGROUND/PURPOSE
The Windsor-Essex County Health Unit (WECHU) is a “health information custodian (HIC)” in accordance with section 3 of the Personal Health Information Protection Act (PHIPA), and an “institution” in accordance with section 2 of the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA). Under this legislation the WECHU has obligations to ensure the rights of individuals with respect to privacy, access, and correction of records of personal information (PI) and personal health information (PHI), and access to general records that pertain to the WECHU operations and governance.
All institutions under MFIPPA, and HICs under PHIPA, are required to provide statistical reports to the Information and Privacy Commissioner of Ontario (IPC) on an annual basis with respect to:
- Confirmed privacy breaches under PHIPA (Appendix A)
- Access and correction requests under PHIPA (Appendix B)
- Access and correction requests under MFIPPA (Appendix C)
The WECHU submitted statistical reports for each category by the required deadline of March 1st for PHIPA reports and March 31st for MFIPPA.
DISCUSSION
Privacy breaches
In 2023, the WECHU had 12 confirmed breaches. Privacy breaches in 2023 predominantly included incidents where Personal Information (PI) and/or Personal Health Information (PHI) was disclosed without authority and emailed or faxed to the wrong person and/or organization.
The WECHU is looking at various ways to prevent breaches of this manner through training and investigating additional electronic information management systems.
MFIPPA access and correction to information requests
In 2023, the WECHU received 18 formal Freedom of Information requests based on MFIPPA, compared to 22 in 2022. All requests were processed within the reporting year.
| Year | Number of MFIPPA Requests | |
|---|---|---|
| Access | Correction | |
| 2023 | 18 | 0 |
| 2022 | 21 | 1 |
PHIPA access and correction to information requests
In 2023, the WECHU received 55 formal Freedom of Information requests based on PHIPA during the reporting year. This was a significant decrease from 2022 due to decreased involvement the WECHU’s support for validating proof of COVID-19 vaccination certification.
| Year | Number of PHIPA Requests | |
|---|---|---|
| Access | Correction | |
| 2023 | 55 | 0 |
| 2022 | 1540 | 169 |
CONCLUSION
In summary, all MFIPPA requests and all PHIPA requests were completed within the statutory time limits in 2023. Priorities for the coming year will include continued dedication of resources for the access to information and privacy program, including additional training, and updated workflows to improve request handling processes. These actions will improve records and information management (RIM) within the program and allow the WECHU to respond with increased efficiency to information requests.