FIPPA And Ontario Hospitals: Setting-Up A FIPPA Compliance Office

This bulletin follows our previous bulletin, FIPPA and Ontario Hospitals: Implementing Change, in which we discussed the operational and cultural changes that are required if hospitals are to fulfill their obligations under the Freedom of Information and Protection of Privacy Act ("FIPPA" or the "Act"). This second bulletin is intended to provide a general overview of how hospitals can structure a central office that will be responsible for FIPPA compliance.

Establishing a compliance office will be a significant task in implementing and operationalizing FIPPA's requirements. While a central office is not a requirement under FIPPA, designating a coordinating body is a practical necessity. The OHA Primer: A Practical Guide for Hospitals Preparing for FIPPA Implementation, published in April 2011, sets out numerous action items and priorities for hospitals to complete prior to January 1, 2012, one of which is establishing a FIPPA compliance office. Accordingly, many