Implementation Guidance Index > Data Consumer Responsibility
Data Consumer Responsibility
Privacy and Security
Prior to implementing this guide, each health information custodian must complete the following, as applicable and specified by Ontario Health: To provide personal health information to Ontario Health as a Prescribed Organization for the purposes of the electronic health record, each health information custodian must:
- Complete all EHR onboarding requirements, as specified by Ontario Health;
- Comply with all applicable Ontario Health privacy and security policies, procedures, and standards; and
- Execute the relevant Ontario Health EHR Contributor Agreements.
To access PHI that is accessible by means of the EHR, each HIC must:
- Complete all EHR onboarding requirements, as specified by Ontario Health;
- Comply with all applicable Ontario Health privacy and security policies, procedures, and standards; and
- Execute the relevant Ontario Health EHR Services Agreements.
In accordance with section 30 of O. Reg. 329/04, the health information custodian is responsible for ensuring that every digital health asset that it selects, develops or uses complies with every applicable interoperability specification, as it may be amended from time to time, and within the time period set out in the specification. In addition to complying with the requirements set out in each applicable interoperability specification, the health information custodian is responsible for complying with PHIPA and its regulations, including but not limited to the health information custodian’s obligations related to ensuring accuracy (section 11(1) of PHIPA), security (section 12 of PHIPA), and the handling of records (section 13 of PHIPA).
System Responsibility for User Authorization, Authentication
System level integration is when a Point of Service (PoS) system representing many users, registers for access to the Patient Summary repository, instead of registering individual users. In this case, access to the Patient Summary repository is granted to the PoS System and all access PoS are treated equally. The responsibility to Authenticate and Authorize individual access is delegated from the Patient Summary repository to the PoS. The PoS must ensure individual users access the patient summary repository as required by Ontario Health’s privacy policies.
The PoS System is responsible for ensuring the accuracy of the identity of the individual requester specified in the message. User identities must be tied to authenticated user accounts.
User Credentials
Any requests for Patient Summary documents must be authorized by the Patient Summary repository. Authorization is granted via a trust model where OAuth2 tokens are exchanged.
The HIC organization under whose authority the interaction is initiated SHALL be identified in the OAuth token.
For any user initiated access to patient summary documents, the individual user must identified by the PoS within the token for auditing purposes within the Patient Summary repository. For system initiated access, where there is no individual user, the user is not required to be identified. Refer to the Connectivity section for further details.
Auditing
The PoS must audit user-initiated activities such as GET or POST requests. Audit logs are maintained by the PoS System to audit PHI disclosure to their end users. PoS Systems must audit PHI disclosed to their end users.
Logging
PoS Systems must log all activities utilizing the Patient Summary Application Programming Interface (API). The PoS System must log all user-initiated activities such as GET or POST requests.
- Application logs are tracked by the PoS System for activities performed by the system. PHI must not be stored in application log files.
- Access logs are tracked by the PoS System when the user accesses the PoS System. PI may be stored in access logs.
- Application logs should log the API request/response HTTP responses codes and operational outcome.
All of the above logs are retained in accordance with the HIC's privacy policies and any supporting agreements with Ontario Health.
Conformance
A Patient Summary resource submitted to Ontario Health SHALL be well-formed and conform with this specification.