Updated - Nurses as Custodians

College & Association of RN of Alberta CARNA has released “Privacy and Management of Health Information: Standards for CARNA’s Regulated Members” For discussion and input. See updated link here. As of September 1, 2011, registered nurses will be considered custodians under the Health Information Act. Custodians also have the opportunity to declare themselves as affiliates to a custodian. The custodian/affiliate must apply to the Minister of Health. (Health Information Act regulation 2.1(1) This process has yet to be determined. Also of note: Where nurses work for an employer who is not a custodian and provide a health service, (section 14) must a. inform the employer of the regulated member's obligations as a custodian b. review the employer's policies and procedures relating to the collection, use, disclosure, retention and security of health information c. make recommendations to the employer . . . d. where the custodian uses the employer's electronic information systems for health information, the custodian shall use reasonable efforts to enter into a written agreement with their employer that addresses their respective obligations regarding the collect, use, disclosure, retention and security of health information If a nuse works independently for an employer who is not a custodian, they must comply with all legislative requirements including (section 16) a. the preparation and submission of a Privacy Impact Assessment to the Privacy Commissioner . . . . Please review the CARNA document for more information. For assistance with policies, procedures, privacy practice reviews, and PIA call Information Managers!