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10.1 Privacy Protection and Information Access Policy

10.1 Privacy Protection and Information Access Policy

This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.

Approving Authority: President

Original Approval Date: December 20, 1995

Date of Most Recent Review/Revision: January 6, 2020

Office of Accountability: Legal Services & Privacy Office

Administrative Responsibility: Privacy Office

1.00 Purpose

1.01 Wilfrid Laurier University is committed to the principles of transparency and the protection of privacy. The purpose of this policy is to provide guidance to those seeking information held by the University or who have concerns regarding how their Personal Information and Personal Health Information are collected, used and disclosed.

1.02 This policy covers obligations with the collection, use, storage and disclosure of Personal Health Information under the Ontario Personal Health Information Protection Act (PHIPA) and Personal Information under the Ontario Freedom of Information and Protection of Privacy Act (FIPPA).

2.00 Definitions

2.01 Personal Information: Recorded information about an identifiable individual, including students, employees, alumni and other members of the University community. Personal Information includes, but is not limited to, an individual’s name, ID number, personal e-mail address, phone number, grades, OneCard photo, and information relating to benefits and accommodations.

2.02 Personal Health Information: Recorded information about an identifiable individual relating to their physical or mental health as it relates to the providing of health care to the individual. This includes, but is not limited to, an individual’s health history, health number or any payments for health care.

2.03 Record: Information however recorded, whether in printed form, on film, by electronic means or otherwise.

2.04 Student Athlete Health Records: Personal Health Information relating to medical treatments (including medical care and treatment by athletic therapists and other regulated health professionals) of student athletes held in the Department of Athletics and Recreation. It is possible for a student athlete to have a Personal Health Information file in the Department of Athletics and Recreation and the Wellness Centre.

3.00 Jurisdiction/Scope

3.01 This policy applies to all members of the University community who collect, use, store, or disclose Personal Information and Personal Health Information on behalf of the University.

3.02 All Personal Information and Personal Health Information collected by the University will be protected, whether the individual is a registered student or not.

3.03 This policy is not intended to restate the provisions of Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA), Personal Health Information Protection Act (PHIPA) or any other access to information and protection of privacy legislation and regulations that apply to the University.

3.04 Records held by separate incorporated entities such as the Wilfrid Laurier Students Union (WLUSU), Graduate Students Association (GSA), and Wilfrid Laurier University Alumni Association (WLUAA) are not within the custody or control of the University.

4.00 Policy

4.01 General (non-personal) Information

4.01.01 Custody and Authority

Those seeking assistance in accessing information of a non-personal nature within the custody and control of the University should direct their request to the University’s Privacy Office.

General Counsel has been delegated responsibility under FIPPA for the oversight of access to information at the University as the University’s Privacy Officer.

4.01.02 Right of Access

Where the University has records of a non-personal nature in its custody and control, access will be granted to the extent possible and in compliance with relevant legislation.

When possible, information of interest to the public and the University community will be posted on the University’s websites (wlu.ca and students.wlu.ca). This includes but is not limited to University policies, approved budget reports, approved audited financial statements, undergraduate and graduate student calendars, and student services information.

4.02 Personal Information

4.02.01 Custody and Authority

Those seeking assistance in accessing information within the custody and control of the University should direct their request to the University’s Privacy Office.

General Counsel has been delegated under FIPPA responsibility for the oversight of access to information and privacy matters at the University as the University’s Privacy Officer.

4.02.02 Right of Access

Pursuant to relevant privacy legislation and subject to any provisions in the legislation, the University shall grant an individual access to their own Personal Information.

4.02.03 Collection, Use and Disclosure of Personal Information

Personal Information is collected under the authority of the Wilfrid Laurier University Act. The University shall collect, use or disclose only such Personal Information as is either necessary to the proper administration of the University or is required by legislative requirements or government mandates.

Unless otherwise noted when the information is collected, Personal Information is collected, used and disclosed in accordance with the University Notice of Collection, Use and Disclosure of Personal Information.

4.02.04 Right of Correction

Individuals have the right to request correction of their Personal Information where the individual believes there is an error or omission. Requests for correction should be submitted to the unit holding the Personal Information. The University shall attach a statement of disagreement to the information reflecting any correction that was requested but not made.

4.02.05 Retention and Disposal of Personal Information

The University shall take reasonable precautions to protect the security of records containing Personal Information, shall retain such information only as long as necessary, and shall make reasonable arrangements for the disposal or destruction of such records when the information is no longer needed.

4.03 Personal Health Information

4.03.01 Custody and Authority

a. Wellness Centre

Those seeking assistance in accessing Personal Health Information within the custody and control of the University should direct their request to the Wellness Centre Director unless the request is for Student Athlete Health Records (see below).

The Wellness Centre Director is the individual responsible for the custody and control of Personal Health Information in the Wellness Centre and is responsible for the oversight of access to these records.

b. Student Athletes

Those seeking assistance in accessing their Student Athlete Health Records should direct their request to the Associate Director of Interuniversity Sport in the Department of Athletics and Recreation.

The Associate Director for Interuniversity Sport is the individual responsible for the custody and control of Student Athlete Health Records held in the Department of Athletics and Recreation and has responsibility for the oversight of access to these records.

c. Contracted HealthCare Providers

The University has contracts with a range of health care providers, for example chiropractic, physiotherapy, and massage. The Personal Health Information records created by these contracted providers are under the custody and control of the contracted provider. Requests for access or correction to these records must be made directly to the contracted health care provider.

4.03.02 Right of Access

Pursuant to relevant privacy legislation and subject to any provisions in the legislation, the University shall grant as individual access to their own Personal Health Information.

4.03.03 Collection, Use and Disclosure of Personal Health Information

Personal Health Information is collected under the authority of the Wilfrid Laurier University Act. The University shall collect, use or disclose Personal Health Information about an individual only with consent of the individual or as permitted or required by law. The University shall use Personal Health Information where the individual has identified that information and consented to its use, for the purpose for which it was obtained or compiled or for a consistent purpose, or in accordance with the relevant legislation. Unless otherwise noted when the information is collected, Personal Health Information is collected, used and disclosed by the Wellness Centre in accordance with the Student Wellness Centre Privacy Statement.

4.03.04 Right of Correction

Individuals have the right to request correction of their Personal Health Information where the individual believes the record is inaccurate or incomplete. Requests for correction should be submitted to the Wellness Centre Director for Personal Health Information held by the Wellness Centre, and the Associate Director for Interuniversity Sport in the Department of Athletics and Recreation for Student Athlete Health Records. The University shall attach a statement of disagreement to the information reflecting any correction that was requested but not made.

4.03.05 Retention and Disposal of Personal Health Information

The University shall take reasonable precautions to protect the security of records containing Personal Health Information, shall retain such information as required by law and shall make reasonable arrangements for the disposal or destruction of such records when the information is no longer required to be retained.