Via email: firstname.lastname@example.org
Health Protection and Surveillance Policy and Programs Branch
Office of the Chief Medical Officer of Health, Public Health
Ministry of Health
393 University Avenue, Suite 2100
Toronto, ON M7A 2S1
Re: Proposed amendments to Ontario Regulation 569 made under the Health Protection and Promotion Act
The Ontario Human Rights Commission (OHRC) welcomes the proposed amendment to Ontario Regulation 569 made under the Health Protection and Promotion Act (HPPA) that would require collecting information on race, income level, language and household size for people who test positive for a novel coronavirus, including COVID-19.
Consistent with its recent public statements, the OHRC recommends the ministry consider expanding the required collection of information to include other vulnerable populations identified in Ontario’s Human Rights Code.
On April 2, 2020, the OHRC released a policy statement and identified actions consistent with a human rights-based approach to managing the COVID-19 pandemic. Among other things, the OHRC highlighted the need for government to collect health and other human rights data on the response to the COVID-19 pandemic, disaggregated by the grounds of Indigenous ancestry, race, ethnic origin, place of origin, citizenship status, age, disability, sexual orientation, gender identity, social condition, etc.
As the Ontario Federation of Indigenous Friendship Centres expressed in a recent letter to the special advisor on the new Ontario Health Data Platform, it is essential that Indigenous health data in particular be included in socio-demographic data collection for COVID-19.
Health and human rights experts agree that Ontario needs demographic data to effectively fight COVID-19. Strong data allows health-care leaders to identify populations at heightened risk of infection or transmission, to efficiently deploy scarce health resources, and to make sure all Ontarians have equal access to public health protections.
The OHRC urges the collection of socio-demographic human rights data through the public health information system as soon as possible. In its April 30 public statement, the OHRC also recognized the need for a longer-term solution to collect human rights information through the OHIP registration form.
cc: Hon. Christine Elliot, Minister of Health
Hon. Merrilee Fullerton, Minister of Long-Term Care
Dr. David Williams, Chief Medical Officer of Health
Matthew Anderson, President and CEO, Ontario Health
Dr. Jane Philpott, Special Advisor, Ministry of Health
Sylvia Maracle, Executive Director, Ontario Federation of Indigenous Friendship Centres
Hon. Doug Downey, Attorney General
Violetta Igneski, OHRC Commissioner
Randall Arsenault, OHRC Commissioner
Dr. Jewel Amoah, OHRC Commissioner