Ontario Medical Students for Patient Privacy
We are Ontario medical students, and we support the recommendations made by the Ontario Information and Privacy Commissioner, Ann Cavoukian, regarding police reporting of suicide attempts, especially as it concerns the release of this information to international governmental agencies. We believe that these measures must be implemented in order to remove barriers for patients receiving emergency care. We are calling on all levels of government to follow and/or implement the recommendations laid out in the Commissioner’s report entitled “Crossing the Line: The Indiscriminate Disclosure of Attempted Suicide Information to U.S. Border Officials via CPIC.” The recommendations from the report are listed below.
Police Services in Ontario should:
1. Immediately cease the practice of automatically uploading or disclosing personal information relating to threats of suicide or attempted suicide via CPIC (Canadian Police Information Centre), by default. Before disclosing personal information via CPIC relating to a threatened suicide or attempted suicide, the Mental Health Disclosure Test (outlined below) must be met. This test requires that one of the following four circumstances exists before any suicide-related information is recorded in the SIP (Special Interest Police) repository of CPIC:
I. The suicide attempt involved the threat of serious violence or harm, or the actual use of serious violence or harm, directed at other individuals;
II. The suicide attempt could reasonably be considered to be an intentional provocation of a lethal response by the police;
III. The individual involved had a history of serious violence or harm to others; or
IV. The suicide attempt occurred while the individual was in police custody.
2. Base any consideration as to the renewal of a Special Interest Police entry on the Mental Health Disclosure Test. In addition, the Police Service involved should take into account any available new information about the circumstances of the individual in question and the length of time since the last attempted suicide.
3. Develop a clear and transparent process to enable individuals to seek the removal of any information on CPIC related to a threat of suicide or attempted suicide. The Mental Health Disclosure Test must be considered when processing a request for removal. In addition, the individual affected should be entitled to volunteer, for serious consideration, information provided from his or her health-care provider regarding the individual’s health and any potential risk to public safety. This process shall be developed by April 16, 2015.
4. Conduct an audit of CPIC to identify all current suicide-related Special Interest Police entries that originated with the service involved. Entries not meeting the Mental Health Disclosure Test should be removed. This audit shall be completed by April 16, 2015.
5. Conduct a review of CPIC entries for specific individuals whose names will be provided by my office. In conducting this review, consideration should be given to the unique circumstances of the individuals and the Mental Health Disclosure Test. This review shall be completed by July 16, 2014.