To summarize the privacy commissioner's thoughts re: bill 46. Netcare will now be managed and operated by the gov. This is not necessarily a concern but a "significant departure" with uncertain benefits. She wonders what consultation w/ health service providers occurred. 1/6

Rules around duties/responsibilities of gov will be elaborated on in regulations. She strongly advises consultation with her on this (which didn't happen pre-bill 46). This bill creates a situation where the gov has "the ability to significantly broaden access to Netcare" 2/6

This includes access out of AB or even CAN. Beyond drs in Lloydminster, she's unsure of the gov's intent but says this will make it difficult for her to "effectively investigate or hold accountable" those out of province and may limit the recourse available to Albertans 3/6

Current rules don't allow health info to be made available via Netcare for purposes like research, education, and management ("Restricted use helps mitigate privacy risk"). Amendments would allow access to Netcare for these purposes. 4/6

Currently custodians must consider pt's expressed wishes in including info in Netcare (can mask the info so only available in emergency). Depending on regulations, these expressed wishes may be limited. She requested detailed consultation on this. 5/6

She finds removal of privacy impact assessment for info shared between Alberta Health, AHS, and HQCA "shocking and disappointing." Some other topics discussed, but those are key issues. The letter: https://www.oipc.ab.ca/media/1111811/letter_minister_shandro_hia_amendments_nov2020.pdf 6/6