PHC Med Staff

• CPSBC Practice Guidelines Overview
• CPSBC Medical Records Documentation
• CPSBC Medical Records Management
• CPSBC Leaving Practice Has relevant information even if you are only moving records and not actually leaving practice

Patient consent: CPSBC guidelines for Medical records management: obtaining patient consent to transfer records include guidance for physicians relocating within the same or neighbouring vicinity. Here, registrants do not need to obtain consent from their patients to move their medical record as this is implied.

Canadian Medical Protective Association (CMPA):

• Retention periods for BC providers, access security, storage, disposal, and transfer.
• Review: How to manage your medical records

• BC Guidelines for Protecting Medical Records Outside the Practice
• BC Physician Privacy Toolkit

Review these guidelines for Protecting Medical Records Outside the Practice.

Always fully protect privacy and confidentiality.

• Arrange for secure transport & storage offsite: another location such as a community or home office.
• Limit records: only those absolute necessity for active continuing care
• Document the removal process: track every file removed with a log: record name, information taken, and date
• Protect privacy and security during transport between locations: Confidential folders in a locked/ secure non-descript container, and remain under your direct control at all times during transport.
• Never leave files in a car, or visible, or take other unnecessary risks to the information.
• Restrict Access: If kept at a private home office, store in a secure, locked filing cabinet or dedicated, secure room with restricted access so unauthorized family or visitors cannot view them.
• Provide written notice to patients:  how to access their records (e.g. contact you). See section below on ‘Notifying Patients” for information and a template notice.
• Notify the College within 14 days of the records relocation, and others as needed. See section below on “Notifying the College” for details.

• Arrange for secure transfer: a qualified off-site storage location. (Suggest: MedRecords, below.)
• Scanning documents (optional): Your qualified provider can scan the records as an option
• Provide written notice to patients. Your qualified provider/MedRecords will provide this service to you.
• Notify the College within 14 days of the records relocation, and others as needed. See section below on “Notifying the College” for details.

• Confirm retention period requirements are met for BC
• DO NOT Shred in PHC / SPH shredding bins.  You need proper documentation.
• Instead, arrange shredding from a qualified provider such as MedRecords
• You must obtain a required Certificate of Destruction.
• Retain the certificate and disposal log on file.

Note: You are legally responsible for the security of patient data until it is completely destroyed. If a data breach occurs or if you are audited, a Certificate of Destruction is your legal proof that you fulfilled your fiduciary duty to securely dispose of that information.  

Provide clear written notice to patients about the change, where their records are stored, and how to access them.  *Subject to the limited exceptions in the Personal Information Protection Act (PIPA)* below

• For active records at a new private location: notify patients of how to access them. (e.g. contact you)
• For stored inactive records: MedRecords  will contact patients on your behalf

Within 14 days: Notify the CPSBC about the new medical records location and how patients can access it.

• Location of the storage facility, or
• If stored in a private office: how to contact you for patient access to the records.
• If a patient requests their medical records, the College will connect you and the patient. They will not share your private address.
• Do NOT share a list the patient records you have moved with the College or others. They do not want a list. Nor should you transfer to anyone else to protect privacy.

Others: In addition to patients and CPSBC, you may need to notify others. Some are involved in of the care of patients.

• A non-exhaustive list is available within the CPSBC Leaving Practice Standard and Doctors of BC Physician Business Services resources for physicians relocating a practice.