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fundamental change in the way in which the hospital operated when it came to requests for information. Kristin Taylor of the Centre for Addiction and Mental Health in Toronto says the process involved making it clear to staff and management at that facility the time had come to update governance policies around information manage- ment. "I felt we really needed to get the mes- know was what records do we have and what do we need to keep. cially considering Taylor said staff was not specifically educated about exemptions or exclusions because she says, "that doesn't help us to have battles going on between our FIPPA office, our FOI office, and the executives who are saying I'm not giving it to you because there' It became an important activity espe- " sage out that we're changing our culture in this area so although we were getting records-retention policies up to speed to make sure we were keeping things for as long as they needed we weren't keeping them longer than needed. It was a great joint effort amongst most of the hospitals in the province to come up with like- minded retention periods," she says. Taylor said communicating the new policy objectives around records retention was a delicate dance. "We wanted to be careful about how we did this because we didn't want the perception to be 'FIPPA' coming, purge!' — that would be the wrong impression. What we needed to s has a right to access a record or part of a record in the custody of a hospital unless it falls within an exemption, the institu- tion concludes on reasonable grounds that the request is frivolous or vexatious, or it falls within an exclusion. Records associated with research, Essentially, under the act, every person s an exclusion." a way of calculating costs, and an inde- pendent body in the form of the infor- mation privacy commissioner reviewing decisions made by hospitals. "This legislation was passed at a time when people didn't generate the kind of data we do today, regional leader of Borden Ladner Gervais LLP' " says Bonnie Freedman, group. Overall, the process of creating a s privacy and access-to-information formal policy for handling information requests has been a positive step forward, says Evans. "A lot of the time we're our own worst mation but the big shift is that with FIPPA it has created a statutory and regulatory regime for requests, setting out exclusions and a time period for processing requests, Celebrating 10 years as Canada' s trusted source for healthcare expert s. The experts you need. The quality you deserve. including clinical trials, are also exempt, except the subject matter and amount of funding received by a hospital for research. Hospitals have always disclosed infor- enemies because we have lots of great records in the organization that describe all the great things we're doing and this is an opportunity to think more proac- tively about getting it out to the public," says Evans. "Often we don't think about the public and what they should have access to. I think when the dust settles and we get rolling on a system this notion of proactive disclosure to the public will move holistically across the organization." IH Support for Corporate Counsel www.CanLNCExperts.ca Experts@CanLNCExperts.ca Untitled-1 1 855-278-9273 (toll free) INHOUSE JUNE/JULY 2012 • 12-05-02 8:38 AM 29

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