Job ID

4 weeks ago


Hamilton, Canada City of Hamilton Full time
Contribute to the City of Hamilton, one of Canada's largest cities - home to a diverse and strong economy, an active and inclusive community, a robust cultural and dining scene, hundreds of kilometers of hiking trails and natural beauty just minutes from the downtown core, and so much more. Join our diverse team of talented and ambitious staff who embody our values of sensational service, courageous change, steadfast integrity, collective ownership and being engaged empowered employees. Help us achieve our vision of being the best place to raise a child and age successfully.

Job ID : PHS Privacy Officer
Union: Non-Union
Job Description ID #: A9393
Close date: Interested applicants please submit your application by 4:00 p.m. on June 26, 2024.

Internal applicants should apply with your work e-mail address . External applicants are considered only after the internal posting process has been completed. Only applicants chosen for an interview will be contacted.

SUMMARY OF DUTIES
Reporting to the Manager, Data Management Program, the PHS Privacy Officer is accountable to the Medical Officer of Health (MOH) as the Public Health Services Health Information Custodian. This position is responsible for leading activities within Public Health Services (PHS in compliance with the Personal Health Information Protection Act, 2004 (PHIPA) and the Municipal Freedom of Information and Protection of Privacy Act RSO 1990 (MFIPPA) and the Health Protection and Promotion Act, R.S.O. 1990. C. H.7. This role also responds to requests for access to records in the custody and control of the MOH, leads investigation of privacy incident reports, supports development of privacy related policies and procedures, makes recommendations on strategy as required and completes required reporting functions to the Information & Privacy Commissioner (IPC) of Ontario.

GENERAL DUTIES
Departmental PHIPA Functions:
Provides advice and guidance with respect to the protection, collection and authorized disclosure of personal health information, including personal information to support the administration and implementation of PHS programs, services and information systems.

Researches, recommends and assists in the development and implementation of policy, guidelines, forms and procedures for the collection of personal health information, its use within PHS programs and applications, disclosure to the public, and the processing of access applications.

Coordinates the execution of Privacy Assessments (including Privacy Impact Assessments, Privacy Audits and Data De-identification Risk Assessments) for new, existing, or enhanced services, business processes and technologies in collaboration with PHS Applications Analysts, PHS Records and Information Management Specialist, PHS Program Managers, Legal Services, IT Security Team, Risk Management, Procurement, PHS Finance and Administration, IT Contract Management and vendors to support compliance with PHIPA, MFIPPA and the HPPA.

Liaises with Legal and IT Security on issues related to contracts/agreements and/or the duty to disclose.

Investigates and leads the response to reported PHIPA breaches and privacy incidents.

Develops and delivers comprehensive training, communication and awareness programs for PHS staff on PHS Privacy Policy compliance and PHIPA matters, in conjunction with the PHS Education Coordinator and the PHS Learning and Development Plan. Conducts ad hoc training sessions for program areas on demand.

Advises on privacy best practices, including the application of privacy by design techniques to ensure privacy is embedded into business practices and the design and operation of PHS tools and applications, processes and data management.

Prepares the statutory annual report on PHIPA activities to the Information and Privacy Commission/Ontario.

Analyzes and prepares the PHS response to applications made under PHIPA and related legislation.

Liaises with PHS program areas to implement business process changes in collaboration with PHS Applications Analysts as appropriate to improve privacy protection practices.

Liaises with program managers and the City Clerk's Division on joint MFIPPA and PHIPA requests to ensure conformity of PHIPA processes with corporate access and privacy policies and procedures, where applicable.
Calculates fees to be charged in accordance with PHIPA.

Reviews, identifies, and analyzes the impact of developments and amendments to legislation, regulations, and decisions of the Information and Privacy Commissioner/Ontario, for PHS senior management and PHS staff.

Assesses PHS implications, recommends appropriate action and implements change, ensures privacy program is reflective of current requirements.

Recommends modifications to PHIPA access requests or the routine disclosure of information to provide effective customer service, as required.

Identifies applicable statutory exemptions and exceptions pertaining to access applications under PHIPA.

Consults with the Program Manager, liaises with legal counsel and prepares representations and submissions in response to mediations or appeals under PHIPA.

Maintains knowledge of emerging trends and potentially contentious issues.

Contributes and maintains required privacy information to the PHS Electronic Records and Information Management Inventory.

Prepares specialized training on PHIPA for Members of Council and/or Public Health Committee and conducts training sessions utilizing both traditional and innovative training methods.

Departmental Privacy Program Functions:
Supports the development and implementation of innovative PHIPA training and its delivery to ensure current and new business processes relating to personal health information are followed, as required.

Provides technical advice and guidance to PHS staff and senior leadership with respect to the protection, collection and authorized use and disclosure of personal health information and coordinates Privacy activities of the Privacy Security and Information Management Committee workplan.

Assists the Program Manager with reported privacy breaches/incidents, provides advice to mitigate their impact and recommends measures to prevent their re-occurrence as appropriate.

Participates in meetings, working groups, and special projects, as assigned.

Completes and coordinates the execution of privacy impact assessments for information systems and applications, in collaboration with program managers and PHS Applications Analysts.

Supports the maintenance of a comprehensive PHS privacy framework and program to support the operation of electronic information systems and applications, including breach protocols, privacy risk assessments, audit protocols and online training materials.

Ensures compliance of PHS electronic information systems and applications with privacy legislation and corporate and PHS privacy policies and procedures, including Personal Information Protection and Electronics Document Act (PIPEDA), PHIPA, MFIPPA, and other related legislation or Electronic Records Management Platform user agreements.

Liaises with the City Clerk's Division on any PHS issues relating to personal information.

Reviews, identifies and analyzes the impact of emerging federal and provincial legislation pertaining to the collection, use and disclosure of personal health information and recommends actions to respond to emerging needs or identified gaps.

Quality Assurance and Due Diligence Activities:
Develops and maintains audit logs and other processes of PHS privacy practices and systems, in order to meet legislated requirements as applicable.

Assists with the development of PHIPA compliance processes and makes recommendations for their improvements, as required.

Analyzes new and/or ad hoc data requests or public reporting for consistency with privacy principles and legislation, including reviewing the details of the data requests, their purposes and authority, and recommends deidentification of data as required to ensure compliance with legislation.

Assists with the development of PHIPA privacy audit standards, guidelines and processes in accordance with PHS access and privacy policies and procedures, where appropriate.

Ensures information, including personal and confidential information, is handled in accordance with legislation and corporate policies, procedures, standards and bylaws.

Collaborates with the City Clerk's Office on matters relating to corporate privacy policies and procedures on personal information.

Liaison, Communication and Customer Service Activities:
Collaborates with the PHS Communications Officer to ensure that the privacy and confidentiality of personal health information is maintained throughout communications with print, broadcast and social media.

Liaises and negotiates responsibilities with Corporate Services including City Clerk's Office, Legal Services, Risk Management and Information Technology.

Assists with the creation of training materials specific to the PHS privacy program.

Makes presentations on privacy, confidentiality, access, disclosure and information security to PHS staff and provides groups with one-on-one support and training (e.g. workshops).

Ensures that services provided meet City of Hamilton customer service standards.

Researches, prepares and responds to correspondence and inquiries from external sources and internal customers at the departmental level.

Other Duties: . click apply for full job details
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