Manager, Privacy Reviews and Consulting

Detailed Overview

Supporting the Vision, Values, Purpose and Commitments of Fraser Health including service delivery that is centered around patients/clients/residents and families: Reporting to the Director, Information Access & Privacy, the Manager, Privacy Reviews and Consulting provides leadership in and is accountable for managing the following areas within the Information Access & Privacy department: Privacy Impact Assessments (PIAs) and general privacy reviews, Information Sharing Agreements and Plans, ongoing requests for privacy consulting across Fraser Health, organization wide Privacy Policies and Procedures, and assistance in the negotiation of contractual privacy terms. The Manager will advise on Fraser Health (FH)’s legal obligations under the Freedom of Information and Protection of Privacy Act (the Act) with respect to privacy protections and compliance relating to the assigned areas. They will develop, implement and maintain key FH privacy policies and procedures and guidance documents based on relevant legislation, best practice privacy standards and Office of the Privacy Commissioner (OIPC) orders and requirements. The Manager works closely with the Information Access, Privacy Auditing and Investigation, Legal, and Risk Management teams on matters involving the Act, and with the Digital Health/Information Technology team on ensuring privacy and security compliance for projects involving technology. The Manager oversees the organization’s Privacy Impact Assessment (PIA) process. Beginning with initial assessments and upstream consulting to determine where a PIA is needed, the Manager and their team conduct detailed reviews of PIAs of all new or changed projects, programs, initiatives or applications involving personal information from across FH’s operating areas to ensure that they comply with relevant privacy legislation. Where appropriate they and their team will propose recommendations that lower privacy risk to the organization, its employees and clients. The Manager will develop and implement processes that identify where an Information Sharing Agreement or Plan is necessary and support the development of those. They will supervise privacy reviews of Surveys, Research Projects, Quality Improvement work and external access requests. Create strategic relationships with FH program leads to provide expertise on compliance with the Act and privacy protection matters within in the broader context of FH’s privacy management program, and work with senior FH staff to promote a culture of compliance across FH. The Manager uses considerable creativity, problem-solving skills and negotiation tactics to ensure compliance with the Act. Engages with multiple stakeholders across key groups within regional health authorities, the Provincial Health Services Authority, and the Ministry of Health. Provides managerial oversight and leadership to the teams within the assigned areas, as well as monitoring expenditures and operating budgets for assigned areas. Responsibilities Leads and manages the assigned areas of: Privacy Impact Assessments (PIAs) and reviews, Information Sharing Agreements and Plans, ongoing requests for privacy consulting across Fraser Health, organization wide Privacy Policies and Procedures, and assistance with the negotiation of contractual privacy terms. Proactively identifies opportunities for improvement and initiates, facilitates and promotes privacy compliance activities within FH. Creates and maintains templates, processes and digital tracking and filing systems that allow their team to complete assigned responsibilities efficiently and effectively and preserve comprehensive decision making records. Uses current case law, OIPC regulatory orders and other privacy guidance documents to advise on and support privacy recommendations, including collection, use, storage and disclosure of personal information. Advises and negotiates information sharing and access agreements in relation to the sharing of personal information with third parties. Builds strategic relationships and collaborations within FH leaders to promote a culture of privacy compliance with the Act. Builds consensus with relevant leaders on compliance requirements in the Act. Partners with program areas such as Virtual Health, Innovation, and Digital Health to form effective working relationships to ensure projects and/or initiatives involving personal information are appropriately implemented and contain effective and efficient privacy access and monitoring controls. Negotiates with third party service providers involved in such projects and/or initiatives in relation to privacy issues. Collaborates with Information Access, Privacy Auditing and Investigations, Legal Services, Risk Management, senior management, program leaders and representatives to ensure FH maintains appropriate documentation for projects and initiatives that involve personal information in line with current legislative requirements. Establishes and oversees central intake processes for the assigned areas by training and supporting intake staff, creating workload trackers and ensuring that workload is triaged according to risk and urgency. Develops performance metrics for the assigned areas, generates reports, and uses such reports and metrics to recommend improvements to practices. Oversees the development and implementation of policies, procedures and guidance documents across FH related to privacy to ensure compliance with the Act. Reviews complex PIAs where the risk level has been scored moderate to high and negotiates suitable remedial actions when required to lower the residual risk. Manages the recruitment, mentoring, selection and professional development of assigned staff. Supervises designated staff, provides work direction and assignment of duties to meet operational requirements. Conducts employee performance reviews and coaching sessions. Facilitates goal setting with employees including the identification of educational and/or training requirements. Implements employee discipline up to and including termination, when necessary. Develops budgets for the assigned areas of responsibility. Monitors expenditures, variance analysis and reporting. Implements corrective action as required. Represents FH as a senior leader on provincial working groups concerning matters related to privacy, research and breach management. Remains current on relevant international, federal and provincial privacy laws and accreditation standards. Monitors for any relevant changes. Shares information and potential implications of such changes with senior management to ensure organizational adaptation and compliance. Represents FH in dealings with the OIPC relating to compliance with the Act where required by the Director. Qualifications QUALIFICATIONS: A level of education, training, and experience equivalent to a Master’s degree in Health Administration, Business (MBA), Information Management or related discipline, plus a minimum of seven years in information management or relevant field including demonstrated experience in managing staff. Completion of the Information Access and Protection of Privacy Certificate Program an asset. COMPETENCIES: Demonstrates the leadership practices of the Fraser Health Leadership Framework of Clear, Caring and Courageous and creates the conditions for people to succeed. Professional/Technical Capabilities Proven ability to lead, inspire, coach, teach, motivate, mentor and support a team. Comprehensive knowledge of privacy legislation, practices and processes. Strong analytical, organizational, communication, interpersonal and administrative skills. Extensive experience and knowledge of British Columbia’s Freedom of Information and Protection of Privacy Act. Demonstrated ability to negotiate effectively and facilitate consensus with internal and external stakeholders. Ability to lead, plan, manage, and problem solve. Knowledge and experience working with the E-Health Act, the Public Health Act, and the Information Management Act. Ability to effectively manage highly emotional and controversial issues.

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