Latest Blog Posts
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Real Risk of Significant Harm (updated)
Amendments to The Freedom of Information and Protection of Privacy Act (FOIP) and The Local Authority Freedom of Information and Protection of Privacy Act in 2018, require that once it is confirmed that a privacy breach occurred, the public body must consider if, as a result of the incident, there is a real risk of... read more
“A” Trustee vs. “THE” Trustee (updated)
If you are reading this blog, I probably don’t need to tell you how complex the healthcare system is. When dealing with The Health Information Protection Act (HIPA), one of the most challenging brain teasers I have to deal with on files is who is the trustee in any given circumstance. When we start to... read more
Data Residency Outside Canada for Trustees
Trustees often ask our office about the use of an information management service provider (IMSP) to manage personal health information. Some want to know about using IMSPs linked to companies outside Canada. Once personal health information leaves Canada, it becomes subject to the laws of the country where it resides. If an individual’s personal health... read more
Absurd Results (updated)
From time to time, when interpreting and applying legislation, one can end up with a result that will be absurd. This can happen from time to time with The Freedom of Information and Protection of Privacy Act (FOIP), The Local Authority Freedom of Information and Protection of Privacy Act (LAFOIP) or The Health Information Protection Act (HIPA). These statutes are to... read more