South East Health Integration Information Portal

TransForm Shared Service Organization (TransForm) as a Health Information Network Provider (HINP)


The Personal Health Information Protection Act, 2004 (PHIPA) establishes a legal privacy framework for protecting Personal Health Information (PHI). The Act provides definitions for terms like “Agent” and “Health Information Custodian (HIC)”and specifies requirements enabling HICs to collect, use, modify, disclose, retain or dispose of PHI via electronic means. PHIPA further specifies requirements for Health Information Network Providers (HINPs) that enable two or more HICs to use electronic means to share PHI.


The Erie St. Clair Local Health Integration Network (ESCLHIN) is creating a computer information portal called the South East Health Integration Information Portal (SHIIP). It will be available through TransForm Shared Service Organization (TransForm) to health care providers, groups or agencies (participants) that are HICs in the geographic area managed by ESCLHIN Health Links, a program designed to identify and support complex/high-needs patients. SHIIP is a secure web-based portal enabling health care providers to share patient data in real or near-real time, including hospital emergency room and acute care visits. The portal incorporates and connects information from existing technology assets, facilitating in the identification of Health Links patients, helping to inform clinical decision and care planning to enhance patient experience. TransForm has entered into a contract with the Kingston, Frontenac, Lennox & Addington Health Unit (KFLA) to provide certain information technology and related services required for the provision of SHIIP. TransForm provides electronic services to HICs for the purposes of providing to, or receiving information from SHIIP.

TransForm functions in different roles as defined in PHIPA when providing SHIIP to participants. To the extent that SHIIP is used to permit two or more participants to disclose PHI to one another related to the coordinated care plan (CCP), TransForm is a HINP to those participants. To the extent that SHIIP is used to permit a participant to use electronic means to disclose or collect PHI, TransForm is a service provider to those participants. Lastly, to the extent that SHIIP is used to generate HARP/LACE scores that identify patients needing extra health care services, TransForm is an agent of the participant that contributed the data used to produce the scores and on whose behalf TransForm is acting in producing the scores.

As a HINP, TransForm is subject to the requirements of PHIPA, subsection 6(3). If you have questions about TransForm’s role as a HINP, or if you require further documents regarding our privacy practices, please make contact with TransForm Privacy Office.

The list of partner organizations who have signed onto this agreement can be provided upon request.

Privacy Impact Assessment (PIA)

A PIA examines a system to determine whether the risks to privacy in that system rise to the level requiring a change in the system or a change in the procedures followed by the people using the system. A PIA also makes recommendations about how risks may be remedied.

The assessment identified 21 privacy risks in Release 3.6.0 of the SHIIP environment at the application and systems level.

Five of the risks are at a High level and the recommendations will be implemented before the system is released for use with patient data.

Three High Risks have recommendations to ensure that TransForm is formally identified in all legal agreements as an agent of the institutions contributing data for SHIIP in relation to generating patient scores that assist clinicians identifying patients needing extra services.

One High risk recommendation was to coordinate descriptions of services by KFL&A support with TransForm support in legal agreements.

The last High risk is satisfied with this web page publically identifying TransForm is hosting the SHIIP service and has appropriate Privacy Controls and risk mitigation programs in place.

The other lower risk findings will be addressed over the next three to six months.

For more information about privacy or security at this organization please contact:

Telephone:
519-437-6264
Email: privacy@transformsso.ca

Or

By Mail:
TransForm Shared Service Organization, Privacy and Security Office
750 Richmond Street Unit A
Chatham ON N7M 5J5

 


Contact Us

Contact Information

750 Richmond St Chatham, ON N7M 5J5