PHIPA DECISION 164

Collection
Health Information and Privacy
Date
File Numbers
PA18-00751
Adjudicators
Jennifer James
Decision Type
Decision - PHIPA
Applicable Legislation
PHIPA - 3(1)
PHIPA - 4(1)
PHIPA - 52(3)
FIPPA - 2(1)

The complainant submitted a request to the hospital for access to video surveillance clips of herself during an involuntary hospitalization ordered under the Mental Health Act. The hospital denied the complainant access to the responsive records. The hospital claims that granting the complainant access to the records could reasonably be expected to result in a risk of serious harm to the treatment or recovery of the complainant or a risk of serious bodily harm to the complainant or another person under section 52(1)(e)(i) of PHIPA.

The adjudicator finds that the records are not “dedicated primarily to” the complainant’s personal health information (PHI). Accordingly, the complainant’s right of access under PHIPA is limited to her PHI that can reasonably be severed from the records. The adjudicator finds that the exemption under section 52(1)(e)(i) of PHIPA does not apply to the records and that the records are comprised wholly of the complainant’s PHI. Accordingly, the adjudicator orders the hospital to grant the complainant access to the records in full.