Investigation Report: PHIA Privacy Impact Review Immunization Card Initiative – Manitoba Health and Manitoba Consumer Protection and Government Services
investigations & monitoring
health facility, body or trustee
Summary
Manitoba Health and Manitoba Consumer Protection and Government Services; review of the privacy implications of the province’s immunization card initiative, a public health response to Covid-19. Manitoba Ombudsman found that the collection, use, and disclosure of personal health information by the departments for the initiative was authorized under PHIA, including being limited to the minimum amount reasonably necessary to accomplish the purpose. Participation was initiated by the individual and was based on informed consent. Written agreements and other security safeguards were in compliance with the requirements of PHIA. The departments made use of tools, such as a privacy impact assessment (PIA), to assist in understanding privacy implications during the development of the initiative and was encouraged by the ombudsman to conduct a PIA for any new uses of initiative technology or personal health information. The ombudsman noted the importance of having a decommissioning plan when the personal health information collected no longer serves a public health purpose.
CASE MO-00342