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Questions and Answers for Information Sharing Guidance

March 19, 2018 • 7 min read

Q1. What is the purpose of the Freedom of Information and Protection of Privacy Act and the Municipal Freedom of Information and Protection of Privacy Act?

The Freedom of Information and Protection of Privacy Act (FIPPA) and the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) have two main purposes:

  • provide a right of access to government records subject to limited and specific exemptions and exclusions, and
  • establish rules to protect individuals’ personal information held by government.

Q2.  What is the role of the Office of the Information and Privacy Commissioner?

In Ontario, the Office of the Information and Privacy Commissioner (IPC) is the designated independent oversight body responsible for ensuring compliance with the three access and privacy laws: The Freedom of Information and Protection of Privacy Act (FIPPA), the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and the Personal Health Information Protection Act (PHIPA). The Commissioner is appointed by and reports to the Legislative Assembly and is independent of the government of the day.

Q3.  What is the Personal Health Information Protection Act?

The Personal Health Information Protection Act (PHIPA) is Ontario’s health-specific privacy legislation that came into effect on November 1, 2004. It covers individuals and organizations in Ontario that are involved in the delivery of health care services including hospitals, pharmacies, laboratories as well as health care providers such as doctors, dentists and nurses. PHIPA governs the manner in which personal health information may be collected, used and disclosed within the health sector.

Q4.  Does this guidance apply to the sharing of personal health information subject to PHIPA? 

No. This document is not intended to provide guidance for organizations governed by PHIPA. It is also not intended to provide legal advice on the interpretation and application of FIPPA and MFIPPA.

Q5.  Does this guidance apply to my organization?

If your organization is subject to FIPPA or MFIPPA, then the guidance applies to you.

  • FIPPA applies to provincial ministries and most provincial agencies, boards and commissions, as well as to hospitals, local health integration networks, universities and community colleges.
  • MFIPPA covers local institutions, such as municipalities, police services boards, libraries, school boards, conservation authorities and transit commissions.

Q6. What does integrated service delivery mean?

Current government services are organized separately and distinctly from one another, and often span multiple ministries. Ontarians may access one or many of these services. When accessing services, Ontarians may be asked to provide personal information such as name and address. When services are not integrated, Ontarians may need to provide the same personal information each time they access or use a program. In integrated service delivery, government programs may be able to share personal information in certain circumstances.

Q7. How will this information sheet support integrated service delivery?

The Ontario government is committed to better serving Ontarians and the communities they live in. In integrated service delivery, agencies and institutions work collaboratively and coordinate the delivery and/or management of supports, servicesand interventions to clients.

This information sheet provides key considerations for municipal service managers, community hubs and associated service providers and is a tool to assist in understanding when personal information may be appropriately shared to better integrate service delivery while protecting privacy.

Q8. What other initiatives are underway to support integrated service delivery?

There are several government initiatives that are working towards integrated service delivery, including the Community Hubs initiative, Human Services Integration, and Benefits Transformation.

  • The Community Hubs Initiative provides leadership, removes barriers, builds capacity and ensures the success of existing and future community hubs.
  • The mandate of Human Services Integration is to support integration of municipally-managed services, such as social assistance, early years and child care programs, and affordable housing and homelessness prevention programs. The goals of this initiative are to simplify client service experience, improve outcomes, enhance system management capacity and strengthen accountability.
  • Benefits Transformation is about improving the way people access income-based benefits programs and making program administration more efficient. Framework legislation, the Benefits Administration Integration Act (BAIA), to enable integrated administration and delivery of income-based benefit programs, was introduced in 2016. Information sharing across programs may be enabled with regulations to be developed under BAIA.

Q9. What are the next steps around Benefits Transformation, and how will this impact information sharing and privacy?

Benefits Transformation will seek proclamation of the BAIA and develop regulations to authorize sharing of personal information between prescribed programs.  Continued engagement with key stakeholders such as provincial ministries, municipal service delivery partners and the Information and Privacy Commissioner of Ontario will be a part of this work.  Once the BAIA is proclaimed and regulations are developed, sharing of personal information may be authorized in limited and specific circumstances (e.g. where it is necessary for administration o

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