Student Wellness Services
Protecting Personal Health Information
Student Wellness Services (SWS) is committed to protecting your privacy and the confidential nature of the information you share. This statement outlines the personal health information practices we use to protect your privacy, and your rights under Ontario law, known as PHIPA (Personal Health Information Protection Act, 2004). This statement applies to individuals accessing physical and mental health care services from a doctor, nurse, occupational therapist, clinical social worker, psychologist, psychotherapist, or psychiatrist at Student Wellness Services.
Collection and Use of your Information
To provide you with quality health care, we keep an electronic record of information about your health status and of the care that we have provided to you. The team of health care providers at SWS uses an integrated electronic health record to document the provision of care. Personal health information is collected, used, and disclosed by Student Wellness Services as permitted or required by law. Your personal health information is only to be accessed by a SWS health care provider or staff member as part of fulfilling their job duties and providing or assisting in the provision of health care.
Consent to Use and Share your Information to Provide you with Health Care
In almost all cases, your consent is required to collect, use, and disclose your personal health information. Consent means you are knowledgeable and informed about the collection, use and disclosure of your personal health information. Consent can be implied (assumed) or explicit (verbal or written).
When you seek health care from us, we assume that we have your permission to collect, use and share your personal health information among the health care providers and administrative staff at SWS who provide or assist in providing health care to you. The sharing of personal health information among the SWS team streamlines and enhances the care provided to you (e.g. a doctor may ask a nurse to call you with lab results; a counsellor may consult a manager etc.).
We also rely on implied consent to share your personal health information on a ‘need-to-know’ basis with other health care providers outside of SWS who are directly involved in your health care (e.g. fax a prescription to your pharmacist, or send a referral to a specialist).
We also rely on implied consent to share personal health information with health insurance providers (e.g. OHIP) for billing-related purposes.
In most cases, your verbal or written consent is required to disclose personal health information from, or with, anyone who is not directly involved in providing or assisting in providing health care services to you (e.g. a family member). See below – “Campus Community”.
Limits to Confidentiality and Requirement of Consent to Receive or Disclose Information
We must also meet legal requirements to disclose personal health information in specific circumstances without your consent (i.e. situations where you are thought to be at risk of harm to yourself or others; a request from a legal authority; in cases of suspected child abuse, elder abuse in a long-term care facility, and sexual abuse by a Regulated Health Care Professional; in cases when a medical condition significantly impairs your ability to operate a motor vehicle).
Withdrawing or Restricting Consent (“Lockbox”) to Access to Personal Health Information
You have the right to withdraw or restrict partial or complete access (other than to those with legal authority under PHIPA) to the personal health information within our health record. If you have concerns related to your privacy or the confidentiality of your information, please speak to your health care provider and we will work with you to address those concerns. Written instructions from you (lockbox form) are required to restrict access to your file. Requesting a lockbox may result in implications for your health care, and possible risks will be reviewed with you individually should you request a lockbox from SWS.
Security and Protection of your Information
We will take reasonable steps to keep accurate records of your health information and will follow all legal requirements and Queen’s security standards and best practice for the security, retention and destruction of these records. All medical records are kept for a period of time determined by the medical licensing authority or other professional oversight body.
All health care professionals and administrative staff at SWS work under PHIPA and adhere to the privacy and security policies of Student Wellness Services. If you become aware of any inappropriate use of your personal health information or a breach of confidentiality, please inform us immediately. Under PHIPA, you may also file a written complaint to Ontario’s Information and Privacy Commissioner.
Access to your Health Record
Unless there are unusual circumstances, you have the right to review and/or obtain copies of your health record. If access or copies are provided, our clinic may charge a reasonable fee to cover our expenses.
Changes to your Health Record
You can request a change to the information in your health record if you think that there is an error or an omission in the record. The health care practitioner will consider your request and either grant or refuse it based on their review. We will place a notation on your health record that you requested the amendment, along with the details of the decision made.
Third Party Consent
If there are individuals in your life whom you wish to have involved in your health care while at Queen’s, we will ask you to sign a SWS Consent regarding Personal Health Information form for each person. Please note you can choose what type of personal health information you want us to receive or disclose and you can withdraw consent at any time.
SWS may be contacted by an individual (e.g. parent/family member, housemate, friend, faculty or staff member, residence life, Student Affairs, campus security, chaplain) who is concerned about your well-being. We will collect information from these individuals and may reach out to you, as appropriate, to follow-up on the concerns that have been brought to our attention, and to connect you to supports if needed. We inform the concerned individual that we may reach out to you, but no additional information will be provided. Please note we do not disclose any personal health information about you or your use of our services at any time, unless there is believed to be an imminent risk to your safety, or the safety of someone else. If you have any questions about personal health information privacy and confidentiality, you may contact the Clinic Manager or the university’s Chief Privacy Officer.
Patients registering with SWS will be provided with this statement, and asked to acknowledge that it has been read, understood and that the practices as outlined, have been accepted.
Queen’s Student Accessibility Services (QSAS)
Queen’s Student Accessibility Services (QSAS) collects, stores, and uses personal and health information as is reasonably required to provide disability-related services under the authority of the Queen's University Royal Charter, 1841 (as amended), and in accordance with the Freedom of Information and Protection of Privacy Act (RSO 1990, c. F.31).
QSAS collects information from students about their disability, functional limitations stemming from their disability, and other disability-related information sufficient to support accommodation planning for studies at university. QSAS also collects information about the student's academic studies at Queen's, including academic status, as well as identifying information such as name, birthdate, contact information, and emergency contact details.
QSAS collects this information to:
- Determine a student's eligibility for accessibility services
- Design and approve appropriate individualized accommodation plans
- Determine eligibility for funding supports (e.g., Bursary for Students with Disabilities, Ontario Student Assistance Program (OSAP), etc.)
- Facilitate referrals to on or off-campus supports and services
- Support informal and/or informal academic appeals, upon request from the student
Collection of Personal Information
QSAS primarily collects information through the disability documentation it requires from students when registering with the service. Information is also collected directly from students through in-person, phone or video meetings, email communications, and from their Queen's student account through SOLUS.
- Students are required to submit their disability documentation to QSAS via upload to our secure server
- Students are advised not to submit their disability documentation to QSAS using email as secure transmission using this medium is not guaranteed
QSAS does not permit indirect collection of personal information without the student's knowledge. Parents or other family members who submit documentation by email to QSAS on behalf of a student must copy the student, preferably using the student's Queen's email address.
In accordance with privacy legislation, students are entitled access to their information held on file at QSAS. Furthermore, QSAS cannot agree to withhold documentation from a student at the request of a parent or other family member, or that which has been submitted without the student's knowledge.
Confidentiality and Protection of Personal Information
The University is committed to maintaining confidentiality to the greatest extent possible when providing academic accommodation and related support services to students with disabilities. All information provided by students including written documentation related to their disability and information disclosed by students to QSAS staff personnel during in-person, phone, or video meetings, or in email communication, is held in strictest confidence.
Student electronic records are kept on an encrypted, secured server maintained by the University Information Technology Services. Only QSAS personnel is authorized access to these student electronic records.
QSAS maintains records for 10 years after the student's last contact with the service. After this time, student records with QSAS are deleted. Students can request copies of their information in their QSAS file even after they have left Queen's for a period of up to 10 years following their last contact.
Use and Disclosure of Personal Information
Within Queen's Student Wellness Services (SWS)
Student information, including information about their disability, the reason for their registration with QSAS, and their accommodation information, is not automatically shared between QSAS and the other units within SWS, including Health and Counselling Services. In situations when consultation and communication between professionals within SWS is required to best support the student, students will be asked to give their explicit consent before these communications occur.
Within the University
QSAS does not share information about a student's disability with anyone else within or external to Queen's University without the student's explicit consent.
Students are not required and are advised not to share any information about their disability with anyone outside of QSAS for the purposes of obtaining academic accommodations.
Information about a student's disability, their registration with QSAS, and/or their receipt of academic accommodations does not appear on any official file with the University, including transcripts, SOLUS accounts, or degree documents.
There are some exceptions where QSAS may be required by law or statute to disclose personal information about students with others. These exceptions include:
- If there is a known risk of serious harm to the student or another person
- In the case of apparent, reported, suspected or potential child abuse or neglect
- In response to a court order or summons for records or testimony
- If a student reports sexual abuse by a Regulated Health Care Professional
- In compassionate circumstances, to facilitate contact with a spouse, a close relative or a friend of an individual who is injured, ill, or deceased
- To an institution or a law enforcement agency in Canada if:
- the disclosure is to aid in an investigation undertaken by the institution or the agency with a view to a law enforcement proceeding, or
- there is a reasonable basis to believe that an offence may have been committed and the disclosure is to enable the institution or the agency to determine whether to conduct an investigation
Sharing of Accommodation-Related Information
Letter of Accommodation
QSAS issues to all students a valid Letter of Accommodation (LoA) once their accommodation plan has been finalized.
The LoA serves as a written agreement between Queen's University and the student outlining the academic accommodations for which they have been approved. No information pertaining to the student's disability is reproduced on the LoA.
QSAS works with students to communicate the accommodation information contained in their LoA to instructors, teaching assistants, academic departmental staff and administrators, and others as required throughout the University in order to ensure all accommodations are properly implemented in a timely fashion. QSAS also shares accommodation information using direct electronic feeds with departments such as the Exams Office, Arts & Science Online, and other units involved with arranging student academic accommodations.
In all of these communications, QSAS shares accommodation information only on a need-to-know basis sufficient to facilitate implementation of the student's accommodations. No information about the student's disability or the reason for their registration with QSAS is ever shared in these communications.
Questions or Concerns
Students can email email@example.com and ask to speak with the QSAS Manager regarding any questions or concerns they have about how their personal information is collected, used, stored, shared, or disclosed.
Student Feedback Procedures
Student Wellness Services (SWS) is committed to providing excellent service for students attending Queen’s University. We welcome both positive feedback as well as suggestions for improvement and take feedback seriously.
To purpose of this procedure is to provide students with a way to voice their feedback and when necessary, find swift and equitable resolution to feedback-initiated issues between students and SWS staff members. This procedure is used when the issue is not covered by another Queen’s University policy, complaint, grievance, or appeal procedure.
Feedback – an oral or written statement of a student’s dissatisfaction with a service, or action(s) of a SWS employee, for which that student is seeking a specific action to address the issue.
Student – any registered Queen’s student utilizing one of SWS service units (QSAS, mental health, medical or Health Promotion)
Respondent – a staff member with whom the student has expressed dissatisfaction
Administrator – the supervisor of the respondent part of the Leadership Team (Physician Lead, Integrated Care Manager, Director of Counselling, Manager of QSAS or Executive Director)
Senior Administrator – next level of management above the Supervisor
Any registered Queen’s student who uses SWS can give feedback online, by calling 613-533-2506 or in-person to an Administrator or designate.
Feedback from the student must be made within 30 calendar days of their visit to SWS. Every effort shall be made by the student and respondent to resolve the issue using the Informal Complaint Procedures; however, the student may choose to enter the Formal Complaint Procedures at any time.
Informal Complaint Procedures
- Student and Respondent schedule a time to meet to review the feedback if needed
- During the meeting, clearly state what the feedback is and if in writing, both retain a copy
- Listen to feedback and seek clarification, if necessary
- If resolution is required, explore ways to come to a resolution
- Agree on a resolution and notify those involved as needed
- If unable to resolve the situation informally, proceed to the Formal Complain Procedure below
Formal Complaint Procedures
- If the student is unable or unwilling to approach the Respondent, or if the concerns have not been resolved informally, the student may initiate the formal feedback process with the appropriate Administrator
- At the meeting, the student presents signed, written feedback containing the following information:
- Detailed description of the situation (including time and date)
- Staff member(s) involved
- Action taken to date
- Action / solution sought
- Within (5) working days of the meeting with the student, the Administrator investigates the feedback. This could include an independent review by a third party (after student information has been removed from the complaint)
- If the feedback has merit, the Administrator will follow up with the staff member and advise the student in writing
- If necessary, the Administrator may bring the student and Respondent together to discuss the situation, clarify the complaint, and develop a strategy to resolve the complaint
- If the feedback lacks merit (e.g. cannot identify a specific area of concern), the Administrator will inform the student in writing and provide reasons why no further action will be taken
- Within (5) working days of receiving the decision of the Administrator, if the student believes the feedback has not been dealt to their satisfaction, the student may appeal the decision in writing
- All documentation provided at the formal feedback level will be reviewed by the Senior Administrator, who will meet with appropriate individuals knowledgeable about the complaint, and make enquiries as needed
- The Senior Administrator will determine the manner in which the complaint will be resolved
- The student will be informed of the decision in writing within (10) business days of receiving the appeal, and that the matter is now closed
- Those investigating feedback shall not be involved in the circumstance as that places them in a conflict of interest in relation to the student
- Receiving feedback may be denied at any time if the student fails to cooperate in the full and timely processing and advancement of the information in the feedback
- Feedback under this process that involves false accusations, malicious intent, or is otherwise made in bad faith, as determined by the investigation, may be considered a violation of the Code of Conduct and Student Procedures for Non-Academic Misconduct