Medical Surveillance - IRCC
As part of the immigration process, Immigration, Refugees, and Citizenship Canada’s (IRCC’s) Migration Health Branch (MHB) provides medical screening and medical assessment services throughout Canada and around the world, pursuant to Paragraph 16(2)(b) of the Immigration and Refugee Protection Act (IRPA).
IRCC has established policies and procedures in line with the protection of public health to prevent inadmissible (under health grounds) individuals from entering Canada. This includes medical surveillance whereby an individual who is found to have inactive pulmonary TB, or latent pulmonary TB, is required to report for a medical follow-up (and possibly treatment requirements) by the provincial or territorial public health authority (P/TPHA) wherein the foreign national resides while in Canada upon arrival in Canada.
Historically, the MHB’s Public Health Liaison Unit (PHLU) has maintained three information systems to support medical surveillance activities. IRCC desired the functionality of these systems to be integrated into its Global Case Management System (GCMS) and that the exchange of information with the P/TPHA be automated. To achieve this goal, in FY 2015-16, IRCC’s Solutions and Information Management Branch (SIMB) developed and implemented new GCMS functionality, as well as a secure web portal for the secure sharing of information with the P/TPHAs. The web portal will facilitate IRCC to exchange information with the P/TPHAs on the medical surveillance requirement.
Given that the P/TPHA often requests, and IRCC discloses, medical information collected as part of the IME (x-rays, laboratory tests, medical history, etc.), a Privacy Impact Assessment (PIA) was conducted to identify any privacy risks to personal information and the appropriate mitigation measures. In addition to medical surveillance, PHLU discloses HIV information on FNs entering Canada.
The sharing of medical records, including HIV information, is authorized under IRPA and Paragraph 8(2)(a) of the Privacy Act (consistent use). The intent of IRCC to collect medical information is the same as that of the P/TPHA in receiving it: to protect the public health (mandated under IRPA) and assist the FN in integration into the Canadian medical system.
The scope of this PIA assessed the sharing of information with the P/TPHAs as it relates to those FNs ordered to comply with the medical surveillance condition, as well as the sharing of HIV data with the P/TPHAs. Additionally, this PIA assessed the privacy risks related to the new GCMS functionality and the secure web portal. As a result of this assessment, seven privacy risks were identified; none of which were assessed as a significant/high risk. Robust risk mitigation activities were developed to address the risks, which will be implemented to alleviate the residual risk before the end of 2016.
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