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Privacy
Impact Statement
System
Overview This
website educates both patients and the public about wait lists and ensures patients
are reasonably informed about their options. The
website allows patients to get data on wait times by surgical category, by hospital,
and by surgeon. To complement this information, the ministry also provides a 1-800
number that patients can
call to find out how best to put this information to use. The
website is monitored by the regional coordinators, and by ministry staff who can
answer patients' questions, and advise them of specialists or hospitals where
more timely care might be available.
Purpose
for Establishing System This
website provides B.C. physicians a single source to check the wait lists of specialists
in their region before referring patients for specialized surgery or treatment.
It also provide
patients with the information they require to make informed choices so that they
are not being delayed for services unnecessarily. Timely
access to surgical procedures is at the core of any health care system.
Collection
of Data Wait
list data has been collected since 1994, from hospitals performing more than 1,000
in-patient and day-care surgeries each year. Only
the ministry can collect the information province wide and provide it to the public
and physicians on a province-wide basis.
Purpose for Collection
The purpose for collection is to monitor and potentially manage health care services
— specifically wait lists and wait times.
Authority for Collection
The Ministry of Health has the authority to collect any personal information contained
in wait list data from health authorities under section
26(c) of the Freedom
of Information and Protection of Privacy Act. The
information relates directly to and is necessary for an operating program or activity
of the ministry. Any
personal information about third parties that the ministry collects from hospitals
is done pursuant to section
27 (1)(b) of the Freedom of Information and Protection of Privacy Act, which
allows the ministry to collect information that may be released to it by another
public body. Hospitals have the authority to release this data to the Ministry
of Health for a consistent purpose under section
33 of the Act. The
Minister of Health derives the mandate to take account of the interests of health
and life among the people of British Columbia from the Health
Act. The
ministry's wait list registry project is an integral component of health care
management within the province. Wait
list management is part of the public accountability process.The
need to monitor and manage wait times is a reality in any jurisdiction with a
public funded health care system.
How Information
is Collected
The Ministry of Health arranges with health authorities to obtain wait list data
from their hospitals. The ministry records and aggregates the reported information
into the Wait List Registry.
Accuracy
of Information There
is an unbroken chain of information flow from surgeon to Ministry of Health. Surgeons
provide hospitals with surgery scheduling information. Hospitals
input the information by trained hospital staff.
The health authorities
capture the electronic data from the hospitals and forward it to the ministry.
The ministry downloads
it directly into the Surgical Wait List Registry. The
ministry receives updated data monthly. Any
errors identified by the ministry are reported back to the hospital, and corrected
by the hospital.
Corrections
Any person identifying errors or
omissions on the website can inform the ministry by using the Feedback
Form. The public and physicians can also use this form to submit requests
for correction, or comments. This input provides the ministry with feedback on
how to improve the accuracy and usefulness of information on the site.
Use
The ministry uses wait list information
supplied by health authorities for the purpose of improving management of health
service delivery. Management strategy for wait lists involves utilization analysis
to make decisions on funding, re-allocation of resources, physician recruitment,
and other practices.
Disclosure
of Information
The information published on the ministry's Internet site is only a subset of
the full data set on which the Wait List Registry is based, and contains:
- Surgeon names;
- Type
of surgery (some specific procedures and some broad categories);
- Number
of patients waiting; and
- Median
wait times.
The
personal information released by the ministry without specific consent, under
section
33.1(c) of the Act, for a consistent purpose. Section
34 defines consistent purpose as "having a reasonable and direct connection"
to the purpose for which the information was originally collected, and "necessary
for … operating a legally authorized program of the public body that uses or discloses
the information." Reasonable
and Direct Connection
This disclosure is consistent with the purpose for which the information was collected
by the ministry — i.e. the broad management of the health care system, and
more specifically the monitoring and management of wait lists and wait times.
Necessity for Operating
Program
The release of surgical wait list information is necessary in order to provide
patients with information they can use to assess their options. They can then
make informed choices to ensure they are not being delayed for services unnecessarily.
Security
The information available on the
ministry website is a discrete subset of the full Wait List Registry. Only the
specific information in this subset is downloaded onto the website server. There
is no link from the subset information to the full Wait List Registry.
Privacy
Impact The
website does not contain any patient identifiers, and its publication should not
have any privacy impact on individual patients. Physician
names and their areas of specialization are already publicly available through
the Ministry of Health or the College of Physicians and Surgeons. In essence,
the wait list number associated with each surgeon is the only "new" information
that has not previously been made public. There is no anticipated harm to individual
surgeons through the release of this information. The invasion of privacy is minimal,
and in the public interest. In
assessing the invasion of privacy, it is helpful to look to section
22 of the Act. The release of wait list information can be said not to constitute
an unreasonable invasion of privacy on grounds analogous to section 22(4)(e) of
the Act, which states that it is not an unreasonable invasion of personal privacy,
if the information released is "about the third party's position, functions, or
remuneration as an officer, employee or member of the public body". Surgeons
operate in publicly funded hospitals, and thus can be said to play a role comparable
to a "member of a public body."
Last Revised: December 18, 2007
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