Collection of Health Information

Drawn from guidance in the Health Information Act Guidelines and Practices 2011.  (For detailed interpretation of this material contact the Information and Privacy Office.)

A custodian must not collect health information except in accordance with the Health Information Act.

A custodian may collect non-identifying health information for any purpose.

An affiliate must only collect the health information that is necessary for that affiliate to carry out his/her responsibilities as assigned by the custodian.

A custodian must collect the least amount of health information at the highest level of anonymity possible unless the collection is for providing a health service or determining the eligibility of an individual to receive a health service.

A custodian may only collect individually identifying health information if the collection is expressly authorized by an enactment of Alberta or Canada or if the information relates directly to and is necessary to enable the custodian to carry out an authorized purpose under section 27 of the Health Information Act.

A custodian must collect individually identifying health information directly from the individual who is the subject of the information, unless indirect collection is authorized under the Act.

A custodian may collect individually identifying health information indirectly (from a person other than the individual it is about) where: 

  • the individual authorizes collection from someone else;
  • the individual is unable to provide the information and the information is collected from the individual’s authorized representative; 
  • direct collection would prejudice the interests of the individual, the purposes of collection or the safety of another individual or would result in the collection of inaccurate information;
  • collection is for the purpose of assembling a family or genetic history needed to provide a health service to the individual;
  • collection is for the purpose of determining or verifying the individual’s eligibility to participate in a program or receive a benefit;
  • collection is for the purpose of informing the Public Trustee or Public Guardian about clients or potential clients;
  • the information is available to the public; or
  • disclosure is authorized under Part 5 of the Act (Disclosure of Health Information).
When collecting individually identifying health information directly from the individual it is about, a custodian must take reasonable steps to inform the individual about the purpose for collection, the legal authority for the collection, and the title, business address and business telephone number of an affiliate who can answer questions about the collection. (See the sample HIA Notification Statement)

A custodian must obtain the consent of the individual or an authorized representative before collecting health information using a recording device or camera that is not obvious to the individual.

The HIA specifies who can request personal health numbers and how the request must be made. 

  • Only a custodian and persons authorized by section 5 of the Health Information Regulation have the right to require an individual to provide their personal health number. 
  • A custodian and a person listed in section 5 of the Health Information Regulation must advise individuals of their authority to collect personal health numbers before they request the number from the individual.
  • An individual can refuse to provide their personal health number to someone other than a custodian or a person listed in section 5 of the Health Information Regulation.

Example HIA Notification Statement



January 2015