Health Information Privacy Policy
Website and Health Information Privacy Policy Document No.: SIP-754-01
Version 1
1. PURPOSE
Fionet Rapid Response Group Inc. (“Fio”, “Fionet”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, integrity, availability, and security of Personal Health Information (“PHI”) and other sensitive personal data processed through Fionet platforms, software products, implementations, services, integrations, analytics systems, and operational support activities.
This Health Information Privacy Policy establishes the principles, governance framework, operational safeguards, and accountability mechanisms governing the collection, access, use, disclosure, storage, transfer, retention, de-identification, and disposal of PHI processed through Fionet systems.
This policy reflects Fionet’s operational reality as a provider of:
Electronic Community Health Information Systems (eCHIS)
Health Facility Electronic Medical Record (EMR) systems
Digital disease surveillance systems
Campaign management and vaccination tracking systems
Laboratory and diagnostic data systems
Clinical decision support systems
Health analytics and reporting platforms
Mobile health applications and offline-first healthcare systems
Health interoperability and integration services
Population health and public health management systems
This policy is intended to align with applicable privacy, data protection, cybersecurity, public health, and health information laws and regulations in jurisdictions where Fio operates, including but not limited to:
Ontario Personal Health Information Protection Act (PHIPA)
HIPAA and related U.S. healthcare privacy requirements where applicable
GDPR and related EU privacy regulations where applicable
Country-specific health information and data residency regulations
National Ministry of Health requirements
Contractual and donor-specific data governance obligations
2. SCOPE
This policy applies to:
All PHI and health-related personal data processed through Fionet products and services
Data collected directly by Fionet or indirectly through customers and implementing partners
Data processed in cloud-hosted, hybrid, and on-premise deployments
Online and offline data collection workflows
Mobile device data collection and synchronization
Integrated systems and third-party interoperability exchanges
Support, maintenance, analytics, implementation, and operational activities
Employees, contractors, consultants, agents, temporary staff, and subprocesses
This policy applies globally unless superseded by stricter local legal or contractual obligations.
This policy does not apply to:
Publicly available information not processed through Fionet systems
Internal employee HR records unrelated to healthcare delivery
Purely anonymized statistical datasets that cannot reasonably identify individuals
3. DEFINITIONS
3.1 Personal Health Information (PHI)
“Personal Health Information” means identifying information relating to an individual’s physical or mental health, healthcare status, healthcare delivery, diagnosis, treatment, medications, laboratory results, vaccination status, reproductive health, disease exposure, referrals, clinical history, public health interactions, biometric or physiological indicators, health identifiers, or healthcare service utilization.
PHI includes information in oral, written, electronic, photographic, biometric, scanned, structured, or unstructured form.
3.2 Personally Identifiable Information (PII)
Information that identifies or could reasonably identify an individual, either directly or indirectly.
3.3 De-identified Information
Information processed to remove or minimize identifying elements such that the risk of re-identification is substantially reduced using reasonable technical and organizational safeguards.
3.4 Health Care
Any health-related observation, examination, diagnosis, treatment, referral, care activity, public health intervention, disease prevention activity, vaccination effort, laboratory procedure, medication dispensing activity, or healthcare service.
3.5 Data Controller / Health Information Custodian
The Ministry of Health, healthcare provider, implementing partner, customer, or organization legally responsible for determining the purposes and means of processing PHI.
3.6 Data Processor / Service Provider
Fionet may act as a data processor, service provider, or agent on behalf of a healthcare provider, Ministry of Health, donor-funded program, NGO, or other authorized data controller.
3.7 Minimum Necessary Principle
The principle that access to PHI shall be limited to the minimum amount necessary to perform authorized functions.
3.8 Security Incident
Any actual or suspected event involving unauthorized access, use, disclosure, modification, destruction, loss, unavailability, corruption, or compromise of systems or data.
4. PRIVACY PRINCIPLES
Fionet’s handling of PHI is guided by the following principles:
Lawfulness and transparency
Purpose limitation
Data minimization
Accuracy and quality
Security and confidentiality
Accountability and auditability
Least privilege access
Storage limitation
Integrity and resilience
Privacy by design and by default
Responsible analytics and de-identification
Respect for patient rights and applicable consent requirements
5. ROLE OF FIONET
Depending on the implementation model, Fionet may operate as:
A software platform provider
A hosted infrastructure provider
A managed services provider
A health information processor
A subcontracted technology partner
A systems integrator
A support and maintenance provider
A public health reporting facilitator
A data migration and interoperability provider
In most implementations, the Ministry of Health, healthcare provider, or implementing organization remains the primary custodian or controller of PHI.
Fionet processes PHI only:
For authorized healthcare delivery and operational purposes
Under contractual authorization
Under documented customer instructions
As required by law
For security, support, and system integrity purposes
For approved public health or reporting obligations
6. PERSONAL HEALTH INFORMATION WE COLLECT
The categories of PHI processed through Fionet systems may include:
6.1 Patient Demographic Information
Full name
Date of birth or estimated age
Sex/gender
Address or settlement information
Phone number
National identifiers
Health insurance identifiers
National health IDs
Family and household linkage information
Caregiver information
GPS or geolocation data where operationally necessary
Biometrics or unique identifiers, where permitted
6.2 Clinical Information
Symptoms and complaints
Diagnoses
Clinical notes
Medications and prescriptions
Allergies
Immunization records
Pregnancy and maternal health information
Newborn and child health records
Laboratory orders and results
Vital signs and physiological measurements
HIV, TB, malaria, and infectious disease information
Referral records
Clinical images and attachments
Treatment outcomes
Disease surveillance information
Community screening records
Risk assessments
6.3 Public Health and Campaign Information
Vaccination campaign participation
Enumeration and registration information
Household visit records
Settlement-level operational information
Disease outbreak tracking data
Contact tracing or exposure data where legally authorized
Population health statistics
Campaign team operational records
6.4 Operational and System Information
Device identifiers
Application logs
User access logs
Audit trails
IP addresses
Synchronization records
Security event records
Offline data synchronization metadata
Session timestamps
User activity records
6.5 Workforce and Provider Information
Healthcare worker identifiers
Professional credentials
Facility assignments
User roles and permissions
Operational performance metrics
7. SOURCES OF INFORMATION
PHI may be collected from:
Patients and caregivers
Healthcare workers
Community health workers
Facilities and laboratories
Ministries of Health
Public health agencies
Mobile applications and medical devices
Integrated third-party systems
Customer-operated workflows
Partner organizations
Public health campaigns and outreach activities
In many deployments, PHI is collected primarily by healthcare providers or Ministries of Health using Fionet systems.
8. LEGAL BASIS AND CONSENT
Fionet processes PHI only where there is a valid legal basis, including:
Patient consent
Healthcare delivery requirements
Public health mandates
Legal or regulatory obligations
Contractual authorization from healthcare custodians
Vital interests of individuals
Legitimate healthcare operations where legally permitted
Where required by applicable law:
Consent shall be informed and appropriately documented
Consent withdrawal mechanisms shall be supported where operationally feasible
Processing limitations associated with withdrawn consent shall be respected unless overridden by law or public health requirements
Certain public health, disease surveillance, vaccination, and outbreak management activities may be conducted under statutory authority without explicit patient consent where permitted by law.
9. PURPOSES OF PROCESSING
PHI may be processed for the following purposes:
9.1 Healthcare Delivery
Patient registration and identification
Clinical documentation
Treatment planning
Care coordination
Referral management
Diagnostic workflows
Medication management
Maternal and child health management
Chronic disease management
Emergency response coordination
9.2 Public Health Operations
Immunization tracking
Disease surveillance
Outbreak response
Population health management
Epidemiological reporting
Campaign execution and monitoring
Health program evaluation
9.3 System Operations
User authentication
System monitoring
Troubleshooting
Technical support
Synchronization management
Backup and disaster recovery
Infrastructure maintenance
Performance optimization
9.4 Security and Compliance
Fraud prevention
Security investigations
Access monitoring
Audit logging
Compliance verification
Incident response
Regulatory reporting
9.5 Analytics and Product Improvement
Where contractually and legally permitted, Fionet may use de-identified or aggregated information for:
System improvement
Workflow optimization
Health analytics
Product enhancement
Capacity planning
Operational reporting
Public health insights
Research and validation activities
Fionet does not use identifiable PHI for marketing directed at patients.
10. DE-IDENTIFICATION AND AGGREGATED DATA
Fionet may create de-identified, anonymized, pseudonymized, or aggregated datasets from PHI where legally and contractually permitted.
De-identification measures may include removal, masking, tokenization, aggregation, suppression, or transformation of:
Names
National identifiers
Phone numbers
Addresses
Dates of birth
Exact GPS coordinates
Device identifiers
Facility-specific identifiers
Direct and indirect identifiers
De-identified datasets may be used for:
Public health analytics
Epidemiological analysis
Product improvement
System validation
Statistical reporting
Research support
Operational optimization
Donor and program reporting
Fionet shall implement reasonable safeguards to reduce re-identification risk.
11. DISCLOSURE OF PERSONAL HEALTH INFORMATION
Fionet does not sell PHI.
PHI may only be disclosed:
To authorized healthcare providers
To authorized Ministries of Health
To approved implementing partners
To authorized public health authorities
To infrastructure or support subprocessors under confidentiality obligations
Under lawful court orders or legal obligations
During emergencies or public health events where legally authorized
As directed by the customer or data controller
All disclosures shall follow the minimum necessary principle.
Where feasible and legally permissible, disclosures shall be logged and auditable.
12. DATA RESIDENCY AND CROSS-BORDER DATA TRANSFERS
Fionet implementations are designed to support country-specific data residency requirements.
In the majority of deployments, PHI and healthcare data are hosted within the respective country’s approved infrastructure environment under the authority or direction of the applicable Ministry of Health, government agency, or authorized healthcare institution.
Depending on country requirements and implementation architecture, systems may be hosted:
On Ministry of Health-managed on-premise infrastructure
Within country-approved government data centers
Within in-country cloud environments
Within customer-controlled infrastructure environments
Fionet does not routinely transfer production PHI outside the country of origin.
Fionet personnel may remotely access systems for authorized support, maintenance, troubleshooting, upgrade, deployment, or operational activities only through customer-authorized and secured access mechanisms, including Ministry of Health-provided VPN connections, bastion hosts, controlled remote access infrastructure, or other approved secure connectivity methods.
Remote access activities are restricted to authorized personnel and are governed by:
Role-based access controls
Authentication requirements
Audit logging
Confidentiality obligations
Customer authorization processes
Security monitoring procedures
Fionet shall not replicate, export, or transfer production PHI outside the hosting jurisdiction unless:
Explicitly authorized by the customer or Ministry of Health
Required for approved disaster recovery or business continuity operations
Required by law
Permitted under applicable contracts and regulations
Necessary for approved interoperability or reporting obligations
Where cross-border access or transfers are legally permitted and operationally necessary, Fionet shall implement appropriate safeguards including:
Contractual protections
Encryption
Access restrictions
Secure remote access controls
Logging and monitoring
Data processing agreements
13. CLOUD HOSTING AND INFRASTRUCTURE
Fionet systems may be deployed:
In customer-owned infrastructure
In Fionet-managed infrastructure
In approved public cloud environments
In hybrid hosting environments
In sovereign or country-specific hosting environments
Infrastructure providers and subprocessors handling PHI must be subject to:
Security reviews
Confidentiality obligations
Access restrictions
Contractual data protection obligations
Incident reporting requirements
14. INFORMATION SECURITY SAFEGUARDS
Fionet maintains administrative, technical, physical, and organizational safeguards designed to protect PHI.
Security controls may include:
14.1 Administrative Controls
Confidentiality agreements
Security awareness training
Role-based access management
Background screening where permitted
Incident response procedures
Vendor risk management
Change management controls
Acceptable use policies
14.2 Technical Controls
Encryption in transit
Encryption at rest where supported
Authentication controls
Multi-factor authentication where implemented
Role-based authorization
Audit logging
Intrusion detection and monitoring
Backup protections
Malware protection
Secure APIs and integration controls
Session management controls
Mobile device protections
14.3 Physical Controls
Secure facilities
Restricted server access
Environmental protections
Device management procedures
14.4 Operational Safeguards
Least privilege access
Segregation of duties
Periodic access reviews
Controlled production access
Secure software development practices
Vulnerability management
Patch management
Disaster recovery planning
Business continuity planning
15. OFFLINE-FIRST AND MOBILE HEALTH SYSTEMS
Many Fionet implementations support offline healthcare delivery workflows.
Where offline functionality exists:
Data may temporarily reside on mobile devices until synchronization occurs
Mobile devices should be physically secured by authorized users
Device-level authentication should be enforced where supported
Synchronization should occur through secured channels
Lost or stolen devices should be reported immediately
Remote disablement or data removal mechanisms may be used where technically feasible
16. ACCESS CONTROL AND USER RESPONSIBILITIES
Access to PHI is restricted to authorized users with legitimate operational need.
Users of Fionet systems must:
Protect login credentials
Avoid credential sharing
Access only information necessary for their duties
Report suspected unauthorized access
Follow customer and Ministry of Health policies
Complete required security training
Fionet reserves the right to monitor and audit system access and usage for compliance and security purposes.
17. AUDIT LOGGING AND MONITORING
Fionet systems may maintain audit logs recording:
User logins
Record access
Data creation and modification
Administrative actions
Synchronization events
Security events
Export activities
API activity
Audit logs may be reviewed for:
Security monitoring
Incident investigations
Compliance reviews
Customer reporting
Fraud detection
Operational troubleshooting
18. RETENTION AND DISPOSAL
PHI shall be retained only for as long as necessary to:
Deliver healthcare services
Meet contractual obligations
Support public health operations
Comply with legal requirements
Meet audit and regulatory obligations
Retention periods may vary by country, implementation, customer contract, donor requirement, or applicable law.
Upon expiration of retention requirements, PHI shall be securely:
Deleted
Destroyed
Archived
Anonymized
Returned to the customer
Disposal methods shall be appropriate to the sensitivity and format of the data.
19. INCIDENT RESPONSE AND BREACH MANAGEMENT
Fionet maintains incident response procedures for actual or suspected privacy or security incidents.
Incident response activities may include:
Containment
Investigation
Risk assessment
Recovery
Notification
Corrective action
Regulatory reporting where required
Root cause analysis
Where required by law or contract, affected customers, authorities, or individuals shall be notified within applicable timelines.
20. ACCESS TO PERSONAL HEALTH INFORMATION
Subject to applicable law and contractual limitations, individuals may request access to PHI held by Fionet or its customers.
Where Fionet acts solely as a processor or service provider, requests may be redirected to the appropriate healthcare provider or Ministry of Health.
Access requests may be denied or limited where:
Disclosure is prohibited by law
The requester cannot be adequately verified
Disclosure may endanger safety
Disclosure may interfere with investigations
The information contains third-party confidential information
Legal privilege applies
The request is abusive, frivolous, or excessive
Reasonable efforts shall be made to respond within applicable legal timelines.
21. CORRECTION OF PERSONAL HEALTH INFORMATION
Individuals may request correction of inaccurate or incomplete PHI.
Where appropriate:
Corrections shall be applied
Amendments shall be logged
Relevant parties may be notified
Disputed information may be annotated
Certain historical clinical records may be preserved without deletion to maintain clinical integrity and auditability.
22. CHILDREN AND VULNERABLE POPULATIONS
Fionet systems frequently support maternal, newborn, child health, immunization, and community health programs.
Additional safeguards may apply to:
Children
Pregnant individuals
Refugees and displaced populations
Vulnerable communities
Sensitive infectious disease programs
Access to sensitive records may be additionally restricted based on program requirements or local law.
23. THIRD-PARTY PROCESSORS AND SUBPROCESSORS
Fionet may engage approved subprocessors or service providers for:
Cloud hosting
Data backup
Monitoring
Technical support
Messaging services
Infrastructure operations
Security services
Analytics support
Subprocessors handling PHI must:
Be contractually bound by confidentiality obligations
Maintain appropriate security safeguards
Process data only for authorized purposes
Notify Fionet of relevant incidents where required
24. INTEROPERABILITY AND SYSTEM INTEGRATIONS
Fionet systems may exchange data with:
National HMIS platforms
EMRs
Laboratory systems
Logistics systems
Identity systems
Surveillance platforms
DHIS2 and related systems
Government registries
Third-party APIs
Such integrations shall be governed through:
Access controls
Secure communication protocols
API authentication
Customer authorization
Data sharing agreements where applicable
25. PRODUCT DEVELOPMENT AND TESTING
Fionet shall avoid using production PHI in non-production environments unless:
Explicitly authorized
Operationally necessary
Adequately protected
Access restricted
Where possible, testing and development environments shall use:
Synthetic data
Masked data
De-identified data
26. TRAINING AND AWARENESS
Fionet personnel with access to PHI shall receive training appropriate to their role, including:
Privacy obligations
Security responsibilities
Incident reporting
Acceptable use
Access management
Data handling requirements
Secure development practices where applicable
Training may be refreshed periodically.
27. PRIVACY BY DESIGN
Fionet incorporates privacy and security considerations into system design and operational processes.
This may include:
Role-based permissions
Configurable access restrictions
Auditability
Encryption support
Secure synchronization
Configurable retention controls
Data minimization approaches
Segregation of environments
API security controls
28. COMPLIANCE, AUDITS, AND GOVERNANCE
Fionet may conduct:
Internal privacy reviews
Security assessments
Access reviews
Compliance monitoring
Vendor assessments
Risk assessments
Penetration testing
Operational audits
Customers may request reasonable compliance documentation subject to confidentiality and security limitations.
29. PRIVACY OFFICER
Fionet shall maintain a designated Privacy Officer responsible for:
Privacy governance
Policy oversight
Incident coordination
Regulatory liaison
Complaint management
Access and correction request coordination
Privacy training oversight
Data protection reviews
Privacy-related inquiries may be directed to:
Privacy Officer Email: privacyofficer@fio.com
30. COMPLAINTS AND REGULATORY RIGHTS
Individuals may submit complaints regarding:
Privacy practices
Unauthorized access
Disclosure concerns
Data correction disputes
Security concerns
Access denials
Fionet shall investigate complaints reasonably and in good faith.
Where applicable, individuals may also contact relevant regulatory authorities or data protection agencies.
31. LIMITATIONS
While Fionet employs reasonable safeguards designed to protect PHI, no system, network, mobile device, or transmission mechanism can be guaranteed to be completely secure.
Customers and users also share responsibility for:
Appropriate device security
Credential management
Local operational controls
Physical protection of equipment
Compliance with applicable procedures
32. POLICY REVIEW AND AMENDMENTS
This policy shall be reviewed periodically and may be updated to reflect:
Regulatory changes
Product evolution
Operational changes
Security requirements
Customer obligations
Emerging risks
Updated versions shall supersede previous versions upon approval and publication.