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1. access any PHI unless the employee or person agrees to comply with the restrictions that apply to KFL amp A Public Health under 1 1 a and b above 2 0 Persons Acting on Behalf of KFL amp A Public Health as ESP 2 1 KFL amp A Public Health shall require employees and persons acting on its behalf in its capacity as an ESP to a execute a confidentiality or other form of agreement that includes the obligations set out in s 1 1 a and b above KINGSTON FRONTENAC AND LENNOX amp ADDINGTON PUBLIC HEALTH BY LAW POLICY amp PROCEDURE MANUAL NUMBER V 52 SUBJECT Electronic Service Provider Procedure PAGE 2 of 2 b successfully complete a privacy training module that encompasses the ORIGINAL DATE 2015 06 24 REVISIONS PHIPA obligations of a ESP and the specific role and obligations of KFL amp A Public Health as an ESP in the circumstances in which the employee or person acts on behalf of KFL amp A Public Health and sign an acknowledgement that indicates the employee or person understood the training module and understands his or her obligations when acting on behalf of KFL amp A Public Health
2. KINGSTON FRONTENAC AND LENNOX amp ADDINGTON PUBLIC HEALTH BY LAW POLICY amp PROCEDURE MANUAL PROCEDURE COMMUNICATIONS APPROVED BY NUMBER V 52 DATE 2015 06 24 PAGE 1 of 2 ELECTRONIC SERVICE PROVIDER Definitions Personal Health Information PHI any identifying information about an individual in oral or recorded form that relates to the individual s physical or mental health health history of the individual s family the provision of health care health card number or identifies the individual s substitute decision maker Source Personal Health Information Protection Act S O 2004 Chapter 3 Schedule A PHIPA Electronic Service Provider ESP a third party that is retained by a health information custodian HIC to assist in providing services to a HIC The services are for the purpose of enabling a HIC to use electronic means to collect use modify disclose retain or dispose of PHI Procedure 1 0 Restrictions on Use and Disclosure of PHI 1 1 Where KFL amp A Public Health is acting as an ESP and is not acting as an agent of the HIC s to whom it provides ESP services KFL amp A Public Health shall a not use any PHI to which it has access in the course of providing the services except as necessary for the purpose of providing those services b not disclose any PHI to which it has access in the course of providing the services and c not permit its employees or any person acting on its behalf to

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