1. Development of a Customized First Nations Privacy & Security Toolkit
Margie Kennedy, Lily Menominee Batise, Nicolette Kaszor
May 28, 2013

2. Presenter Disclosure Presenters No Conflict of Interest Margie Kennedy
Lily Menominee Batise
Nicolette Kaszor
No Conflict of Interest

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
Transition to NK for Slides 4-6 inclusive

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

5. Project Guidance

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
Transition to LAMB for Slide 7-12

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
Check fonts

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)
OCAPTM 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

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)

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

11. From the Community Perspective…

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
Iterations led by Privacy & Security Sub Group in consultation with project team. Priorities of ease of use, literacy burden, and scalability guided revisions and refinement of the tools.

13. Privacy Assessment

14. Toolkit Resources Confidentiality Agreement 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
Transition to MK for Slides inclusive

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
The final version of the Privacy video was released in October 2012 and is available via the Chiefs of Ontario website. The Toolkit contains 2 assessments and 24 tools as well as several appendices providing supporting resources. The Toolkit was developed and refined over a period of 24 months, and involved the Privacy & Security Toolkit Working Group, volunteer community reviewers, and iterative refinement cycles. The Toolkit was approved for use among Initial Subscribers in November 2012.

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

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

18. For more information on the P&S Toolkit:
Chiefs of Ontario
Lily Menominee-Batise

19. Questions & Discussion
Meegwetch Nia:wen
Thank you
Questions & Discussion