Guidelines for Appropriate Use of the Internet, Electronic Networking and Other Media

Date of original approval: 2008
Date of last revision and approval: PGMEAC April 2008; HUEC June 2008; HUEC 2020; Faculty Council October 16, 2023

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Scope

These Guidelines apply to all Temerty Medicine learners, including those registered or participating in educational activities affiliated with the Temerty Medicine, who may in the course of their studies, training and/or research activities have contact with patients and/or patient information.

Internet, electronic networking and other media includes emails sent or received, email accounts, digital music, digital photographs, digital means and videos, social networks, file sharing accounts, other online accounts and similar digital items which currently exist or may exist as technology develops, regardless of the ownership of a physical device or digital item that is stored.

The use of the Internet, electronic networking and other media includes but is not limited to posting/commenting on blogs; direct messaging (DM), instant messaging (IM), private messaging (PM) on social networking sites; posting to public media sites, mailing lists and video-sites; and emails.

These Guidelines are informed by but do not replace or limit the standards established by professional or regulatory bodies; by relevant clinical settings; or by other applicable University or Faculty standards, guidelines, policies, and procedures, including those referenced throughout this document and listed in Appendix A.

Preamble

The capacity to record, store and transmit information in electronic format brings specific responsibilities to those working in healthcare with respect to privacy of patient information and ensuring public trust in our hospitals, institutions and practices. Significant educational benefits can be derived from this technology and learners need to be aware that there are also potential problems and liabilities associated with its use. Material that identifies patients, institutions or colleagues and is intentionally or unintentionally placed in the public domain may constitute a breach of law, standards of professionalism and confidentiality that damages the profession and our institutions. Guidance for Temerty Medicine learners about appropriate use of the Internet, electronic networking and other media is necessary to avoid problems while maintaining the University of Toronto’s commitment to freedom of expression.

Various statements, policies, protocols, codes and standards apply to social media communications (see Appendix A). In particular, no member of the University should engage in hate speech or in behaviour that demeans, harasses, or intimidates others; nor should any community member be subject to such language or behaviours in the course of their University work or study. The University is committed to providing support to members of our community who are experiencing harassment or intimidation in social media spaces and to exploring intervention options via its policies and procedures or through its Community Safety Office, and/or municipal law enforcement where circumstances permit.

Postgraduate learners are reminded that they must meet multiple obligations in their capacity as university learners, as members of their profession and relevant professional regulatory bodies, and as employees of hospitals and other institutions. Undergraduate and professional master’s learners are reminded that they must meet multiple obligations in their capacity as university students and as future members of their professions. For all Temerty Medicine learners, these obligations extend to the use of the Internet, electronic networking and other media at any time – whether in a private or public forum.

General Guidelines for Safe Use of the Internet, Electronic Networking and Other Media

These Guidelines are based on several foundational principles, as follows:

• The importance of privacy and confidentiality to the development of trust between health care practitioner and patient.
• Respect for colleagues and co-workers in an inter-professional environment.
• The importance of ensuring the tone and content of electronic conversations remain professional.
• Individuals are personally responsible for the content published on or disseminated using the Internet, electronic networking or other media.
• The assumption that material published on or disseminated using the internet, electronic networking or other media is permanent.
• All involved in health care have an obligation to maintain the privacy and security of patient records under the Personal Health Information Protection Act (PHIPA), which defines a record as “information in any form or in any medium, whether in written, printed, photographic or electronic form or otherwise”.

1. Professional Behaviour

All Temerty Medicine learners will engage in behaviour that displays and reflects truth, honesty, representation in, on and around electronic platforms and/or devices. Learners are to engage only in on-line activities that are respectful and exemplify professional behaviour.

Inappropriate use of the Internet, electronic networking or other media may breach University of Toronto codes of behaviour, including the Code of Student Conduct, Policy on Sexual Violence and Sexual Harassment, Statement on Prohibited Discrimination and Discriminatory Harassment, and Standards of Professional Practice Behaviour for all Health Professional Students. Inappropriate use of the Internet, electronic networking or other media may also breach standards established by professional or regulatory bodies, including for medical learners the CPSO Social Media Policy.

Faculty members and learners should not participate in industry marketing, sales or sponsorship programs with industry, including via the internet, electronic networking and other media.

2. Posting Information about Patients

Never post personal health information about an individual patient.

Personal health information (PHI) is defined in the Personal Health Information Protection Act (PHIPA) as any information about an individual in oral or recorded form, where the information “identifies an individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify an individual”.

These guidelines apply even if the individual patient is the only person who may be able to identify theirself on the basis of the posted description. Learners should ensure that anonymised descriptions do not contain information that will enable any person, including people who have access to other sources of information about a patient, to identify the individuals described.

Further guidance is provided in the Temerty Medicine Statement on Protection of Personal Health Information, which sets out requirements to ensure appropriate access to and use of Personal Health Information in affiliated teaching sites’ custody by Temerty Medicine learners.

Exceptions that would be considered appropriate use of the Internet, electronic networking and other media.

It is appropriate to post information about patients:

1. With the express consent of the patient or substitute decision-maker.
2. Within secure internal hospital networks if expressly approved by the hospital or institution. Please refer to the specific internal policies of your hospital or institution.
3. Within specific secure course-based environments provided by the University of Toronto that are password-protected or have otherwise been made secure. Even within these course-based environments, participants should:
   1. adopt practices to “anonymise” individuals;
   2. ensure there are no patient identifiers associated with presentation materials; and
   3. use objective rather than subjective language to describe patient behaviour. For these purposes, all events involving an individual patient should be described as objectively as possible, i.e., describe a hostile person by simply stating the facts, such as what the person said or did and surrounding circumstances or response of staff, without using derogatory or judgmental language.

4. When using entirely fictionalized accounts that are so labelled.

3. Professional Communication With and Posting Information About Colleagues, Supervisors, and Co-Workers

Respect for colleagues, supervisors, and co-workers, including their privacy rights, is important in an interprofessional working environment. Addressing colleagues and co-workers in a manner that is insulting, abusive or demeaning is unprofessional behaviour. Making demeaning or insulting comments about colleagues and co-workers to third parties, including via the Internet, electronic networking and other media, is also unprofessional behaviour. If you are in doubt about whether it is appropriate to post any information about colleagues and co-workers, ask for their explicit permission – preferably in writing.

Insulting, abusive or demeaning comments and communication may breach University of Toronto codes of behaviour and/or standards established by professional or regulatory bodies, including those referenced in (a) above.

4. Posting Information Concerning Hospitals or other Institutions

Learners should comply with hospital or institutional policies regarding the use of technology as well as the use of any proprietary information such as logos or mastheads.

Learners must not represent or imply that they are expressing the opinion of the organization. Be aware of the need for a hospital as well as the University of Toronto to maintain the public trust. Consult with the appropriate resources such as the relevant communications or public relations office at the hospital or Temerty Medicine.

5. Offering Clinical Advice

Do not misrepresent or mislead as to your qualifications or role.

The provision of medical advice by postgraduate medical learners is governed by the terms of their registration with the College of Physicians and Surgeons of Ontario, which limits the provision of medical advice by postgraduate learners within the context of the teaching environment. Provision of medical advice by postgraduate medical learners outside of this context is inconsistent with the terms of educational registration.

Similarly, the provision of clinical advice by other professional clinical learners is governed by the terms of their registration with their professional regulatory bodies.

6. Academic Integrity Extends to the Appropriate Use of the Internet, Electronic Networking and Other Media

The University of Toronto's Code of Behaviour on Academic Matters articulates offences that are considered a breach of academic integrity; these offenses may occur in-person or online. These offences include plagiarism and forms of cheating such as sharing examination questions or collaborating on work where specifically instructed not to do so.

Enforcement (Disclosure and Reporting)

All professionals have a collective professional duty to assure appropriate behaviour, particularly in matters of privacy and confidentiality.

If an individual observes or experiences a Temerty Medicine learner potentially breaching these Guidelines, and if the individual feels comfortable, willing, and judges that it is safe to do so, they may choose to approach the learner and communicate their concerns with the goal of ending the behaviour. This approach recognizes the important role of collegial conversation in the medical community and emphasizes the principle of addressing problems locally and on a case-by-case basis wherever possible.

However, if such a conversation is inappropriate in the circumstances (e.g., it has previously been ineffective, the issue has potential mandatory reporting obligations, or if more support is required due to a significant power imbalance) then an individual who observes or experiences concerning behaviour may disclose their concerns to an appropriate University leader or office (e.g., their course or program director, Office of Learner Affairs, Learner Experience Unit). Such concerns will be addressed on a case-by-case basis, in accordance with the relevant guidelines and procedures.

Complaints about breaches of privacy may be filed with the institutional privacy office and the Information and Privacy Commissioner of Ontario.

Consequences for Inappropriate Use of the Internet, Electronic Networking and Other Media

Consequences for inappropriate use of the Internet, electronic networking and other media would depend on the nature and severity of the conduct, and the applicable policy, and could include, but is not limited to:

• Remediation, failure to promote, probation or dismissal by the Temerty Faculty of Medicine
• A finding of professional misconduct by the College of Physicians and Surgeons of Ontario or other professional regulatory body
• Prosecution or a lawsuit for damages for a contravention of the PHIPA

Appendix A – Associated Statements, Policies, Protocols, Codes and Standards

University of Toronto

• Appropriate Use of Information and Communication Technology
• Code of Student Conduct
• Standards of Professional Practice Behaviour for all Health Professional Students
• Statement on Prohibited Discrimination and Discriminatory Harassment
• Policy on Sexual Violence and Sexual Harassment
• Protocol with Health Care Institutions: Sexual Violence and Sexual Harassment Complaints involving Faculty Members and Students of the University of Toronto arising in Independent Research Institutions, Health Care Institutions and Teaching Agencies
• Code of Behaviour on Academic Matters

Temerty Faculty of Medicine

• Temerty Medicine Statement on Protection of Personal Health Information
• MD Program Student Mistreatment Protocol
• PGME Guideline for Managing Disclosures about Learner Mistreatment

College of Physician and Surgeons of Ontario

• Social Media policy and Advice to the Profession companion document
• Professional Responsibilities in Medical Education policy
• Protecting Personal Health Information policy
• Physician Behavior in the Professional Environment policy and Guidebook for Managing Disruptive Physician Behaviour

Government of Ontario

• Ontario Human Rights Code
• Personal Health Information Protection Act
• Information and Privacy Commissioner of Ontario

Hospitals and research institutes affiliated with the University of Toronto

• Contact the relevant hospital/research centre