A Privacy Impact Assessment (PIA) helps ensure that your business is operating in compliance with Alberta’s Health Information Act (HIA). A PIA also helps prevent privacy breaches and protects your business if a breach does occur. Under the HIA, Chiropractors in Alberta are required to submit a PIA to the Privacy Commissioner of Alberta.
If you have not yet completed a PIA for your clinic, you should seriously consider doing so as soon as possible to avoid any future data breaches. This blog post will explain how PIAs help chiropractors in Alberta create safer environments for their patients’ private information, and why it’s so important to get your PIA right.
(Scroll to the bottom to get your copy of the 2022 PIA Provider Checklist)
What is a PIA?
A PIA is a process by which your clinic evaluates the privacy risk that its programs, processes, and policies present to the private patient information in your care. It is not a one-time activity but instead, should be updated periodically to reflect changes to your practice or the industry. Going through the PIA process, you will identify and assess any risks to privacy that you can plan and implement steps to minimize privacy breaches and avoid problems with privacy compliance.
A PIA can take many forms, butin Alberta the Office of the Information and Privacy Commissioner (OIPC) has set criteria for what information must be included and how your PIA must be structured. Privacy compliance is a complex topic. Consulting an expert on privacy requirements and completing a PIA can help protect against mistakes or oversights that could cause harm to patient privacy and delay your protection against breaches.
Benefits of completing a PIA
A Privacy Impact Assessment is an exercise undertaken by healthcare clinics to identify risks to patient privacy (ways breaches could happen) and document reasonable measures taken to mitigate that risk. A properly structured PIA creates the foundation for compliant clinic operations that actively avoid privacy breaches.
With privacy breaches on the rise across healthcare, the benefits of completing a PIA include better protecting personal information from breaches, providing a referenceable framework for staff to evaluate their actions and processes, and the comfort of knowing you are operating in compliance with regulations. Your PIA will establish guidelines for organizational change management as data governance requirements continue to evolve.
An accepted PIA also demonstrates due diligence and compliance with privacy legislation. In the event of a breach, proof that you were and are operating under reasonable safeguards will reduce the risk of regulatory repercussions such as fines and sanctions.
How does a PIA help prevent privacy breaches?
A Privacy Impact Assessment identifies where and how patient information is vulnerable, and documenting the safeguards in place to help prevent privacy breaches. The process also identifies gaps in physical and information security that might need to be addressed. For example, some common cyber threats that cause breaches are ransomware and phishing scams that staff can be trained to identify and block. Your PIA can catch deficiencies in vendor software that also need to be addressed for the protection of your patients and your practice.
The actions of clinic staff are historically the most common cause of privacy breaches. Your PIA is a living document that reflects the steps team members need to take to prevent privacy breaches. In that way it is a critical training document that must be reviewed upon hire and updated regularly.
Can I do a PIA myself?
Completing a Privacy Impact Assessment is not a simple task. Just like chiropractors spend years studying mechanical disorders of the entire musculoskeletal system, certified privacy compliance experts study to understand the whole picture of privacy risks and safeguards in individuale clinic contexts.
Imagine if a patient took on diagnosis and treatment of their own condition. They could read text books and continuing education articles about chiropractic treatment, but would they be successful? Maybe. But, they will probably do more damage than good.
It’s important that Chiropractors implement appropriate safeguards ASAP because the privacy landscape is evolving quickly. Mandatory breach reporting means clinics that suffer a breach often end up in the news. Delays in PIA acceptance can lead to privacy breaches due to unchecked operating procedures and training gaps.
Clinics that take on completion of their PIA often underestimate the time commitment involved (the final document can be over 200 pages long), and ignore the fact that a PIA needs to be kept up to date with changes internally and from a regulatory perspective. While it is true that submission of a PIA meets the HIA requirement, in the event of a breach you will need to show compliant operating policies and procedures.
Until a self prepared PIA is accepted (a process that can take 2 years), you have no certainty of compliance and security. Working with experts removes the guesswork from your privacy breach prevention strategies and lets you move forward with confidence that your patients and your practice are protected.
Evaluate your Options:
It’s hard to know which partners provide the best value if you aren’t fully aware of what’s required to establish and maintain compliance. Download the latest PIA Provider Checklist to understand what could and should be included in your privacy support.