Personal Health Information Privacy Policy (PHIPA)
For COVID-19 Testing Services
Entomogen Inc. (“Entomogen”), is committed to protecting your privacy, and will collect, use, store and disclose your personal health information only for the purposes outlined in this policy, which is governed by the Personal Health Information Protection Act, 2004 (PHIPA). Entomogen ensures that its privacy policies and procedures are compliant with all relevant privacy legislation.
Collection and Use of your Personal Health Information
In order to provide its COVID-19 testing services, Entomogen, through its division emDx, will need to collect certain personal information, such as your name, date of birth, contact details, health card number (if provided), as well as your test results (collectively ‘personal health information’).
Entomogen will use your information for the following purposes:
· To confirm your identity and match your samples with your test results
· For any other purpose mandated by law
De-identified samples may be used for quality assurance/quality control purposes, such as monitoring, evaluation and reporting, and may be sent to another laboratory for confirmatory testing.
If a test is positive for COVID-19, the de-identified sample may be sent for sequencing to another laboratory as part of a study to determine what variants are circulating in Ontario.
Disclosure of Your Personal Health Information
Entomogen will limit the collection and disclosure of your personal health information to the purposes identified in this Policy. Entomogen will disclose your personal health information:
· To the healthcare provider who ordered the test (the ‘requisitioner’)
· To In-Common Laboratories in order to facilitate the uploading of information to the Ontario Laboratories Information System (OLIS)
· As otherwise required or permitted by law, legal process or government request
· PLEASE NOTE that all COVID-19 test results must be uploaded to OLIS. In addition, positive COVID-19 test results must be reported to the appropriate Public Health Unit for contact tracing and quarantine instructions.
Withdrawal or Reinstatement of Consent for Access to Information in OLIS
You may withdraw or reinstate consent for the Ministry of Health and Long-Term Care (MOHLTC) and/or healthcare providers who have not ordered your laboratory tests to view your laboratory test information and results contained in OLIS. If you choose to withdraw your consent, only the healthcare provider who ordered the test will be able to see the results in OLIS. The MOHLTC and/or health care providers who have not ordered your laboratory tests will not have access to this information through OLIS. Choosing to withdraw your consent will not affect your relationship with your health care provider(s), who will continue to provide care to you.
To withdraw or reinstate consent, please download and fill in the appropriate form below and send it to emDx@entomogen.ca at the time the test is ordered.
Withdrawal of consent form (English):
Withdrawal of consent form (French)
Reinstatement of consent form (English):
Reinstatement of consent form (French):
Additional information about OLIS, and links to the withdrawal and reinstatement of consent forms, may also be found in the MOHLTC Health Bulletin here: http://www.health.gov.on.ca/en/news/bulletin/2010/20101119.aspx
You may also contact ServiceOntario at 1-800-291-1405 or TTY 1-800-387-5559 if you have any questions, or wish to withdraw or reinstate your consent in OLIS.
PLEASE NOTE: For public health reasons, you may not withdraw consent for positive COVID-19 test results to be reported to the appropriate Public Health Unit.
Security of your personal information
Entomogen takes all reasonable precautions to ensure that your personal information is secure and protected from loss, theft, unauthorized access, modification, use, copying, or disclosure. Our safeguards include:
· Physical security includes:
o Locked filing cabinets
o Restricted office access and alarm systems
· Technological security includes the use of:
o Passwords and user IDs
o File encryption
o Firewalls and virus scanners
· Administrative controls include:
o Written security rules
o Staff training
o Access restrictions
o Regular audits to ensure compliance with security policies
o Confidentiality agreements
· Electronic records controls include:
o Passwords and User IDs to prevent unauthorized access
o Automatic back-up for file recovery to protect records from loss or damage
o Digital audit trail for all records
Record Retention and Disposal
Entomogen will retain your personal health information for seven (7) years, after which time we will destroy, erase or anonymize it.
Entomogen will dispose of your records (including electronic records and hard copies) in a secure manner that protects your privacy, including supervised cross-shredding of paper records, and magnetically erasing or overwriting electronic records, in such a way that the information cannot be recovered.
Results reported to OLIS will be retained according to applicable regulations.
Corrections
If you would like to request correction(s) to be made to your personal information, please contact the emDx Laboratory Director at lbarelli@entomogen.ca .
Privacy Complaints
If you have an enquiry or complaint about Entomogen’s information practices, or its collection, use and/or disclosure of your personal health information, please contact Entomogen’s Privacy Officer at Privacy@entomogen.ca in the first instance.
If Entomogen does not address your enquiry or complaint to your satisfaction, you may file a written complaint with the Information and Privacy Commissioner (IPC). Details regarding complaints to the IPC may be found here: https://www.ipc.on.ca/health-organizations/phipa-complaint-process/
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