Should you provide your child’s HSN to their school?
Have you ever filled out a form for your child’s school and wondered if they really need all the information they are asking for? Among other personal information, your child’s school might request their health services number (HSN). The Commissioner has not yet dealt with this issue in a formal report so this is just food for thought.
The Health Information Protection Act (HIPA) sets out the rules as to what is personal health information and when it can be collected, used, and disclosed by health organizations and health care workers. HIPA defines who is responsible under the Act and refers to these organizations and individuals as trustees; schools are not listed as a trustee.
An individual’s HSN is considered their personal health information and under HIPA also provides that an individual is not required to provide their HSN unless they are receiving a health care service or otherwise where required by another Act or regulation. An individual’s personal health information is considered more sensitive than other personal information and HIPA provides that personal health information shall be collected on a need-to-know basis. Does your child’s school have a need-to-know your child’s personal health information?
You may think that the school is requesting your child’s HSN in the event that your child is injured at school and requires a trip to the doctor’s office or hospital, the parent or guardian will be called to pick up the child or meet the child at the health care facility. Chances are, in an emergency, the school will not be searching through their records to find the child’s HSN. The health care facility will not refuse to treat your child and will collect personal information from the parent or guardian once you arrive at the facility. In another scenario, your child may be offered an immunization at school, but this service is not offered by the school and will be offered by a trustee. You also have the right to consent each time a health service might be offered to your child. If you consent to the service, the trustee has a need to know and your child’s HSN can be collected by the trustee at that time.
Although you may have thought the school collects the HSN for health care purposes, on its Privacy and Access in Saskatchewan School’s website, the Saskatchewan School Boards Association (SSBA) identifies reasons why students’ HSN might be requested. For more information on the SSBA’s position, here is the link to its website: https://saskschoolsprivacy.com/central-adminstration/student-records/use-access-disclosure-of-student-records/disclosure-of-saskatchewan-health-numbers/. Although the HSN is a unique identifier, issued to all Saskatchewan residents, it is personal health information; it is not a form of identification that should be used broadly and is issued for the primary purpose of obtaining health care services.
If a school requests your child’s HSN and an individual refuses to provide the number, if the school continues to insist, you can submit your concerns to the school board’s privacy officer. If your concerns are not addressed to your satisfaction, you have the right to contact our office.
It is common for schools to request that parents provide their child’s HSN when enrolling the child, but parents do have the right to ask the school why they need it and have the choice whether they wish to provide it or not.