Reporting to the Regional Manager, Records Management & Registration or designate, the HIM Freedom of Information (FOI) Analyst is responsible for performing specialized analytical and technical work involving pre-authorizing and responding to requests of a complex, sensitive and non-routine nature for information specific to health records for specialized services (such as BC Corrections Services). Requests often involve high volumes of information, multiple sources of information requiring liaison and coordination with other agencies on redactions and the completion of additional procedural requirements. The FOI Analyst is accountable for ensuring HIM compliance with all requirements of the Freedom of Information & Protection of Privacy Act (FOIPPA) on behalf of the serviced organization including full application of Part 2 of the Act. Liaises regularly with applicants (current and former clients), legal counsel, specialized institute (e.g. BC Corrections) and Health Authority officials (e.g., Information Privacy Office, Risk Management) to ensure requests are clearly defined, review potential risks, legal and security issues regarding the release of inmate or former inmate information. Prepares documentation and briefing material for mediation by the Officer of the Information and Privacy Commission as required. Provides education and advice to HIM leadership on difficult requests and/or new developments in practice.
Thorough knowledge and understanding of FOIPPA and related legislation.
Ability to understand and apply organizational policies, procedures and standards.
Ability to exercise sound judgment in recognizing scope of authority and protecting confidential information.
Demonstrated service orientation.
Demonstrated time management skills.
Excellent verbal, written, analytical and communication skills.
Ability to work effectively independently and in a team environment.
Demonstrated analytical, research and problem solving skills.
Proven attention to detail and accuracy in work.
Ability to work effectively with stakeholders and others internal and external to the organization.
Ability to handle situations where conflict may arise and seek satisfactory resolutions.
Ability to handle confidential and sensitive information with tact and discretion.
Ability to lead, coach and teach others.
Ability to operate related equipment including use of standard office desktop computer applications such as Microsoft Suite (Word, Excel, PowerPoint, Access).
Ability to access and use electronic records and databases.
Physical ability to perform the duties of the position.
A level of education, training and experience equivalent to a Diploma in a relevant field such as Information Management , Privacy, Information Access, Public Administration or other related discipline plus one to two years’ experience performing analytical work and interpreting and applying Freedom of Information/Privacy legislation policies and directives.
Reviews, analyzes, recommends, develops and pre-authorizes responses to complex, sensitive and non-routine FOI clinical requests for information within specified timeframes.
Reviews and determines the nature and extent of information requests, making preliminary decisions, such as whether the request is within the specialized institute (e.g. BC Corrections) and/or HIM’s jurisdiction or if another public body has a greater interest.
Analyzes requested records to determine if any mandatory or discretionary exceptions specified in FOIPPA apply and what materials can be released ensuring risks, legal and security issues to the author, applicant, third parties and/or the specialized service are considered.
Makes determinations to involve Regional Manager or other senior leaders if there are any extraordinary issues that arise during the processing of a request.
Interprets and applies FOIPPA and other regulations and severs required information, in accordance with statutory requirements, prior to the release of information.
Acts as a liaison on behalf of the serviced organization when responses to requests for review or complaints are made to the Office of the Information and Privacy Commissioner.
Reviews and discusses requests with applicants or their legal counsel to ensure requests are clearly defined, the FOI process is clearly understood, and to narrow or clarify the scope of the request.
Reviews records provided to determine if they are within the scope of the request and to ensure that all relevant records have been provided.
Works with stakeholders to anticipate complexities, gather facts, identify resource requirements, develop alternatives and coordinate a timely response.
Discusses time extensions or multiple releases of information for complex or extensive requests with Regional Manager and specialized services leaders and applies for time extensions under the Act where required.
Prepares arguments, in consultation with Manager, specialized services leaders and risk/legal advisors, to defend or justify decisions relating to the disclosure or withholding of information.
Prepares documentation and briefing material for mediation by the Officer of the Information and Privacy Commission as required.
Advises and educates specialized services staff, HIM and Health Authority staff on legislative obligations around the duty to assist FOI applicants and adequate searches for records.
Works independently with the ability to manage caseloads and works effectively with other FOI team members.
Participates in the preparation of policies, procedures and standards, in house educational and training materials and delivers in-services and training sessions as required.
Determines if a fee, as prescribed by the Act, can be applied and prepares a fee estimate where appropriate.
Maintains appropriate file documentation and notes.
Performs other related duties as required.