Your Role as a Health Information Custodian – Some Facts to Share

There is considerable value in the data stored in electronic medical records (EMRs). A number of external stakeholders including pharma companies and pharmacy networks have expressed interest in exporting these data, better to support the patient journey.

We would advise our members to familiarize themselves with some recommended resources which define some of the commonly used terms such as Health Information Custodian vs Agent, Prescribed Entity, guidelines for data sharing, and what happens if there has been a privacy breach. Breaching these rules risks bringing your practice under the scrutiny of the  Information Privacy Commissioner (IPC). 

Use caution before you share information with any unlicensed medical care provider or a non-prescribed entity. Feel free to reach out to the ORA if you have questions around a data sharing opportunity. We can help guide your decision by sharing some of our knowledge.

A final word: Please note that the ORA Ontario Rheumatic Disease Evaluation Registry (ORDER) project adheres to a comprehensive Data Governance Framework to ensure that we are fully compliant with PHIPA. We consulted with a third-party legal entity to guide us in our development of a rheumatology dashboard that will be integrated on the EMRs of members who choose to participate. More information coming on this soon!

Recommended Online Publications:

  1. Frequently Asked Questions: The Personal Health Information Protection Act (PHIPA). Link:
  1. The Canadian Medical Protective Association has also published an online resource titled Electronic Records Handbook.  Link: publications/handbooks/com_electronic_records_handbook-e.pd