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Frequently Asked Questions

Below is a list of commonly asked questions about research privacy at PHSA. If you would like to submit an additional question, please contact the research privacy advisor.

Please note that the responses are for guidance only and do not constitute legal advice. Please contact the research privacy advisor if you have specific legal questions and the appropriate consultation will be arranged.

PHSA research privacy review

‎No. Only studies that use or link personal information or have significant privacy concerns are reviewed by the research privacy advisor. See our checklist of activities that lead to significant privacy concerns for research studies.

‎If you are using or linking personal information your study will likely require a privacy review. If you are unsure, please contact your REB or the research privacy advisor.

‎‎No. Your REB will provide the research privacy advisor with access to your study on RISe so there is no need to submit additional paperwork.

The research privacy advisor aims to complete reviews at the same time as the REB review. This usually takes approximately three business days but more time may be necessary if additional information is required from the study team in order to complete the review.

Privacy regulation and guidance

‎According to the Freedom of Information and Protection of Privacy Act (British Columbia) (“FIPPA”), the definition of personal information is quite broad. Schedule 1 of this Act defines it as follows:  “recorded information about an identifiable individual other than contact information.” The Act defines contact information as  “information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual”.

‎FIPPA is an acronym for the Freedom of Information and Protection of Privacy Act (British Columbia). It is also sometimes referred to as FOIPPA.  According to its Government of BC website, the purpose of the Act is “to make public bodies more accountable to the public and to protect personal privacy.” FIPPA only applies to public bodies like PHSA. It does not apply to private sector organizations.

‎TCPS2 is the central Canadian guidance document that aims to promote the ethical conduct of research involving humans. As stated on its website, the Tri-Council Policy Statement: Ethical Conduct for Research Involving Humans ("TCPS" or "the Policy") is a joint policy of Canada’s three federal research agencies – the Canadian Institutes of Health Research (CIHR), the Natural Sciences and Engineering Research Council of Canada (NSERC), and the Social Sciences and Humanities Research Council of Canada (SSHRC), or “the Agencies.”

To be eligible to receive and administer research funds from the Agencies, institutions must agree to comply with a number of Agency policies set out as schedules to an Agreement between the Agencies and institutions. Institutions must therefore ensure that research conducted under their auspices adhere to this Policy. Researchers are expected, as a condition of funding, to adhere to the TCPS. Institutions should support their efforts to do so.”

‎In some cases it is difficult to determine if a study is research as defined by TCPS2. Some types of research that are exempt from REB review are presented in Chapter 2 of TCPS2.  However, final determinations should be made after consulting with your REB. 

The Panel on Research Ethics offers TCPS2 interpretations regarding this issue that you might find helpful. For example, they point out that “publishing or otherwise disseminating the results of an activity is not a factor that determines whether the activity is research or not”. They also suggest using a tool like the Alberta Research Ethics Community Consensus Initiative (ARECCI) to help determine if your study is research as defined by TCPS2 or quality assurance.

Privacy breaches must be reported to your REB and to the PHSA Information Access & Privacy Office (IAP). Both bodies have careful procedures for helping you to deal with these issues appropriately. If you need help navigating this process, please contact the Research Privacy Advisor for support. 

For more information, please visit the PHSA IAP webpage* and UBC REB Guidance Note webpage and Key Contacts.

*Note: Only accessible when connected to PHSA POD.
Complementing Research Ethics Board Review

‎Although REB reviews address issues like privacy and confidentiality according to TCPS2 and other guidance documents and regulations, reviewing for compliance with FIPPA is considered beyond the scope of REB review. The privacy review conducted by the research privacy advisor is intended to support REB processes, not duplicate their work.

‎The research privacy advisor’s reviews are guided by FIPPA, TCPS2, and other ethics principles, guidance documents and regulations. When reviewing studies that involve data sharing, the research privacy advisor wants to ensure that you have a plan to manage the data safely throughout the lifecycle of your research study.

‎The research privacy advisor can conduct privacy reviews in conjunction with the C&W REB, BC Cancer REB, UBC CREB, and UBC BREB on RISe and has already made arrangements with these REBs to do so when required. If your study is being submitted to a REB that is not on this list, simply contact the research privacy advisor and she will reach out to the REB in question.

‎No. The changes only apply to research studies as defined by Article 2.1 in TCPS2.  If you have questions about privacy for REB exempted studies please contact PHSA's Information Access & Privacy Office (IAP).

SOURCE: Frequently Asked Questions ( )
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