First Nation Panorama Deployment in Ontario Development of a Customized First Nations Privacy &...
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First Nation Panorama Deployment in Ontario Development of a Customized First Nations Privacy & Security Toolkit Margie Kennedy, Lily Menominee Batise, Nicolette Kaszor May 28, 2013
First Nation Panorama Deployment in Ontario Development of a Customized First Nations Privacy & Security Toolkit Margie Kennedy, Lily Menominee Batise,
First Nation Panorama Deployment in Ontario Development of a
Customized First Nations Privacy & Security Toolkit Margie
Kennedy, Lily Menominee Batise, Nicolette Kaszor May 28, 2013
Slide 2
Presenter Disclosure Presenters Margie Kennedy Lily Menominee
Batise Nicolette Kaszor No Conflict of Interest 2
Slide 3
Objectives Highlight the unique privacy needs and challenges of
First Nations Highlight the development of a Privacy and Security
plan for the First Nation Panorama Deployment in Ontario (FNPDiO)
Project Identify community needs that informed development Provide
an overview of the Privacy & Security Toolkit Identify
priorities and anticipated uses of the Toolkit Share the partner
model adopted to ensure broad partner engagement and development
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Slide 4
FNPDiO Evolution Governance: Tri-partite partnership Chiefs of
Ontario, First Nations and Inuit Health Branch, and the Ontario
Ministry of Health and Long Term Care Mandate to deploy Panorama to
all First Nations in Ontario who wish to do so Started in 2007
Technical and Policy Direction Knowledge Management Advisory Group
(KMAG) Various Working groups Privacy, Data Management, Change
Management, Information Management/ Information Technology,
Communications 4
Slide 5
Project Guidance 5
Slide 6
Privacy Innovation Broad perspective on First Nation privacy as
an enabler for eHealth initiatives First customized development of
a privacy plan and associated resources informed by First Nation
needs and priorities 6
Slide 7
Privacy and Security Priorities at the Community Level Overall
plan Meet current needs (Panorama deployment) Support capacity
development in First Nations Be scalable for future eHealth
developments Principles Easy to understand & use Ready for
immediate use by First Nations with varying human resources
Deliverables Video Toolkit Engagement Leverage knowledge of First
Nation Initial Subscribers for subsequent deployment & use
Privacy Sub-Group to lead development 7
Slide 8
Unique Privacy Needs of First Nations Small communities
resource constraints, etc. Not every community has extensive health
personnel to engage in projects Balancing the PHI protection vs the
value of community support where in a small community, everybody
knows your business First Nation/band administration professional
development General principles and execution of health information
privacy Provincial legislation (PHIPA) OCAP TM principles need to
be embedded in any solution related to First Nation information
Ownership, Control, Access, and Possession Consistent protection of
PHI in health care settings and in the communities 8
Slide 9
Privacy Challenges among First Nations Non-standard privacy
procedures Each First Nation is independent and may have own
internal practices, laws, and/or policies Reconciling varying
privacy requirements Variable community-based privacy
infrastructure Many First Nations have limited privacy
infrastructure to support health delivery Resources Resources who
have experience and can take on the responsibility for privacy
leadership and accountability (e.g. privacy officers)
Political/governance factors Understanding of privacy obligations
by Health Information Custodian (HIC) 9
Slide 10
FNPDiO Privacy Video Developed in collaboration with FNPDiO
Privacy Working Group, and representatives from the Initial
Subscribers and the FNPDiO Elder Advisor Focus on the value and
priority of privacy related to health information from a First
Nations perspective URL for Privacy Video
http://www.youtube.com/watch?v=Uu-iBSj7ypg&feature=youtu.be
http://www.youtube.com/watch?v=Uu-iBSj7ypg&feature=youtu.be
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Slide 11
From the Community Perspective 11
Slide 12
FNPDiO Privacy & Security Toolkit Purpose Comprehensive
resource to assess current state and gaps Provide tools that will
cover the gaps Components Two Assessments Privacy Security Tools
Templates for immediate use Fact Sheets Frequently Asked Questions
(FAQs) Glossary, PHIPA Obligations, additional resources
Methodology Conduct assessments to identify gaps Use tools Review
gaps 12
Slide 13
Privacy Assessment 13
Slide 14
Toolkit Resources PRIVACY Privacy Policy Responsibilities of
Privacy Contact Staff FAQs Confidentiality Agreement Privacy Notice
Client FAQs Staff Guide for Consent Consent templates Immunization
General PHI Inventory Tool De-identifying PHI Record of Assessment:
Determination of Capacity to Consent Request for for PHI SECURITY
Security Policy Business Continuity Management Plan Access to
Network Services Request Form Acceptable Use Policy IT Asset
Management Inventory Mobile Devices Security Fact Sheet Faxing PHI
Fact Sheet Privacy & Security Incident Response Plan P&S
Breach Investigation Report Notice of Breach Letter to Clients
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Slide 15
FNPDiO Toolkit Use Outcomes Communities reviewed existing
policies and resources Within Health facilities/portfolio Across
operations Tools in the Toolkit were used to: Generate completely
new policy structures Fill gaps Supplement existing policies
Identify Privacy Resources to comply with PHIPA Privacy Officer
Privacy Notice 15
Slide 16
Next Steps Updates based on experience with pilot use Future
versions of the FNPDiO Privacy & Security Toolkit For use with
Secondary Subscribers Share Initial Subscriber Privacy Policies
with other First Nations general distribution/availability to
others interested or potentially benefitting from this work after
September 2013 16
Slide 17
Acknowledgements The presenters acknowledge the contributions
of the members of the Knowledge Management Advisory Group (KMAG),
our First Nation Elder Advisor Barney Batise, and the Privacy Sub-
Committee in the development of this plan and Toolkit Pam Nolan
(Co-Chair) Ida Cornelius (Co-Chair) Krista Yao Cheri Corbiere and
community reviewers Nipissing First Nation Mohawks of Akwesasne
Garden River First Nation 17