::: Thames Valley Midwives :::

In order to provide you with appropriate prenatal, labour and delivery and postpartum care, it is necessary for us to collect a significant amount of personal information about you, your family/partner and the biological father of your baby. We recognize the importance of protecting your privacy and are committed to collecting, utilizing, and disclosing any information about you in a responsible manner and only to the extent necessary for the services we provide. This document explains our privacy policy.

Personal Information

Information about an identifiable individual is personal information and is protected by privacy legislation. This includes information about personal characteristics (e.g. age, home address or phone number, ethnic background, family status), health (e.g. health history, conditions, services received) or activities or views (e.g. religion, politics, opinions). Business information (e.g. an individual’s business address) is not protected by privacy legislation. In order to provide you with appropriate care, we will also need to collect health history information regarding the father and grandparents of your baby. The requirement to reveal this information to named family members is still under debate in legal and regulatory circles.

Our organization

Thames Valley Midwives, at the time of this writing, includes five registered midwives, one practice manager and two part-time office staff. We also contract with a bookkeeper, accountant, lawyer, cleaner and computer consultants that may, in the course of their duties, have limited access to personal information we hold. Our practice is a teaching facility for the Ontario Universities’ Midwifery Education Programme, the International Midwives Pre-registration Project, the University of Western Ontario School of Nursing and the University of British Columbia Faculty of Medicine and as such, students from any of these programs may have access to personal information during the course of their clinical placements with us. We do restrict the unnecessary access to personal information and require a signed agreement with each individual indicating that they understand and will abide by our privacy policy.

Primary purposes for the collection of personal information

As with all health care providers, we are required to collect personal information in order to provide appropriate care to our clients. We initially collect information about your general health history, including your family history, and physical condition in order to assess whether your obstetric care needs fall within the scope of midwifery care. We will subsequently collect detailed information about your health, family health history, and social situation in order to provide you with the most appropriate care possible within the practice of Informed Choice as required by the College of Midwives of Ontario. By obtaining health information early on in your care, we are also able to determine when significant changes occur, allowing us to care for you and your baby in the best way possible. It would be rare for us to collect or use such information without your express consent, but this might occur in an emergency situation (e.g. a communicable disease outbreak).

Related and Secondary Purposes for Collecting Personal Information

Some of the purposes listed below are optional and specific to our practice; you are free to inform us if you do not wish your personal information to be used for a particular purpose. Some, however, are required by external regulatory bodies (e.g. Ministry of Health and Long Term Care, College of Midwives of Ontario). The most common examples of our related and secondary purposes for collecting personal information are as below:

To invoice the Ministry of Health and Long Term Care (MoHLTC) (through our local transfer payment agency, St. Joseph’s Health Care, London) for services provided by registered midwives. The MoHLTC requests that we submit information about your care to them in the form of a “Client Tracking Sheet.” This sheet is available for you to inspect. Only upon your signed consent will this form include identifying information (your and your baby’s Ontario Health Care number).
To advise you about events that we hold for our clients (e.g. our annual summer picnic). You can let us know if you do not wish to be on the list used for this purpose only.
To inform our insurer of potential claims.
To meet the regulatory requirements of the College of Midwives of Ontario (CMO). As part of their mandate to regulate midwifery care in the public interest, the CMO has the authority to inspect our records and interview our staff. The CMO has its own strict privacy obligations.
To fulfill legal requirements with respect to reporting. As professionals, we are required to report serious misconduct, incompetence or incapacity of other practitioners, whether they are midwives or other regulated professionals. We are also required to report any child protection concerns to the appropriate authorities.
To fulfill legal obligations to the Governments of Ontario and Canada. Various government agencies (e.g. Canada Customs and Revenue Agency, the Information and Privacy Commissioner and the Human Rights Commission) also have the authority to review our files and interview our staff. In some cases, we may need to disclose information to our legal counsel or insurers.
To communicate necessary information to other health professionals and services. Some of your care may include utilizing the services of other professionals (e.g. radiologists, genetic counselors, medical laboratory technologists). In order to properly provide care, these professionals will require that we disclose some of your personal information to them. In addition, should your or your baby’s care require consultation with a specialist (obstetrician, paediatrician) we will disclose the appropriate information to them. All of these professionals are regulated under PIPEDA and will have their own privacy policies.
To meet the information needs of third party payers. The costs of some of the services you will receive (e.g. laboratory work, radiology) are paid by third parties (e.g. OHIP, UHIP) who require some disclosure of personal information.
To facilitate shared billing between two practices. If we provide care to you along with another midwifery practice in the province of Ontario, we must complete an “Interpractice Care Agreement” in concert with that practice. In this document, we determine which practice is responsible for reporting to and invoicing the Ministry of Health and Long-Term Care.
If Thames Valley Midwives or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the practice’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser.

Protecting Personal Information

We take the utmost care to ensure that your personal information is protected from unnecessary disclosure. The following steps are undertaken to do so:

Paper copies of your information are kept in our office in locked file cabinets. The office is locked when not occupied and the building is locked with a security alarm in the evenings and on weekends. Charts that are transported from the London office to hospital or our clinics in St. Thomas or Ingersoll or to home births are kept locked and out of sight at all times.

When we need to mail or fax your information to the hospital or another care provider or consultant, the communication is clearly marked “private and confidential.”

After you leave our care, the paper copy of your file is kept in our office in a locked file cabinet for approximately one year. After that period the information in the file is scanned onto an archival CD-ROM. This process is carried out by a reputable, bonded corporation. The CD-ROM is kept locked in a safe in our office and the data are also stored on the St. Joseph’s Health Care network in a password-protected file. The paper copy of the chart is destroyed.

Electronic hardware is kept secure in our offices and the doors are locked when not occupied. Passwords are used on all computers and only care providers and support staff have access to the passwords for files containing personal information. Each midwife and our practice manager carries a personal data assistant (such as a Palm Pilot) that may contain lists of clients with their contact information. These devices are all password protected.

Destruction and removal of information

The College of Midwives of Ontario requires midwives to store client files for 10 years after discharge from care (and 10 years after the age of majority for infants). Once a year, such outdated files will be deleted from our electronic systems and the appropriate storage discs will be destroyed.

Access to information

You have the right to see any personal information about you or your baby. We will be happy to provide you with copies of the information with appropriate notice. If necessary we can also help you interpret medical language and short forms that may be included in your information. If you do not agree with the information as it is presented corrections can be made to information that was originally provided by you. While we cannot change the assessments made by a health practitioner, we can document any differences of opinion. Other individuals listed in your chart (e.g. your partner and/or the father of your baby) may have access to the information directly related to them.

Exceptions to the above

If we need to use your personal information for reasons not listed in this document, we will obtain your permission first. Exceptions to this are as follows:

Where collection or disclosure of information is clearly in your interests and consent cannot be obtained in a timely way (e.g. An emergency that threatens the life, health or security of an individual)

Where collection or use is to investigate a breach of Canadian law or agreement and knowledge or consent would compromise the investigation. In such an instance, the practice would be so instructed by investigative authorities (by, for example, subpoena or warrant).

Where information is available to the general public (for example, in telephone directories)

Questions?

Our Privacy Information Officer, Monica Toth, can be reached at:

434 Maitland Street, Suite #1 London ON N6B 2Z2
Phone: (519) 433-5855
Monica.Toth@sjhc.london.on.ca

She will attempt to answer questions or concerns that you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint, ensure that it is investigated properly and that you are provided with a formal decision and reasons in writing.

This policy is made under the Personal Information and Electronic Documents Act. This act also sets out some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the
administration of the privacy legislation in the private sector. The Commissioner can be contacted at:

112 Kent Street, Ottawa, Ontario, K1A 1H3
Phone: (613) 995-8210, Toll-Free 1-800-282-1376, Fax: (613) 947-6850, TTY (613) 992-9190

http://www.privcom.gc.ca