Privacy: Compliance for Clinics in Ontario

Clinics operating in Ontario are required to comply with provincial and federal privacy legislation governing the collection, use, disclosure, and protection of personal information, including personal health information.

This article provides an overview of the main privacy obligations for Ontario clinics and explains how Colib supports clinics in meeting these requirements. This content is provided for informational purposes only and does not constitute legal advice.

# Privacy Laws Applicable in Ontario

Personal Health Information Protection Act (PHIPA)

In Ontario, the primary privacy law governing health information is the Personal Health Information Protection Act (PHIPA).

PHIPA applies to health information custodians (HICs), including private clinics and regulated health professionals, when they collect, use, or disclose personal health information (PHI) in the course of providing care.

PHIPA establishes rules for:

• How PHI may be collected, used, and disclosed

• The safeguards required to protect PHI

• Patients’ rights to access and request corrections to their records

• Transparency around information practices

Personal Information Protection and Electronic Documents Act (PIPEDA)

In addition to PHIPA, clinics in Ontario may also be subject to PIPEDA, Canada’s federal private-sector privacy law.

While PHIPA generally takes precedence for clinical records and health care delivery in Ontario, PIPEDA may still apply in certain situations, including:

• Handling non-health personal information

• Commercial or administrative activities not directly related to care

• Communications or data exchanges that fall under federal jurisdiction

As a result, many Ontario clinics operate under both PHIPA and PIPEDA, depending on the type of information involved.

# Core Privacy Principles

Across both PHIPA and PIPEDA, clinics are expected to follow key privacy principles, including:

• Collecting, using, and disclosing information only for appropriate and lawful purposes

• Limiting collection to what is necessary

• Obtaining consent where required

• Protecting information against unauthorized access, use, or disclosure

• Keeping information accurate and up to date

• Allowing individuals to access and request corrections to their information

• Being transparent about privacy practices

# How Colib Supports Privacy Compliance

Colib is designed to help clinics implement reasonable administrative, technical, and organizational safeguards in support of their privacy obligations.

? Access Controls & User Management

• Individual user accounts with unique credentials

• Role-based access controls defined by the clinic

• Two-Factor Authentication (2FA) to strengthen account security

• IP restrictions (when necessary) to limit access to approved networks or locations

These measures help ensure that only authorized individuals can access client information.

# Accountability & Auditability

• Activity logs record access and modifications to client data

• Clinic owners can monitor usage and investigate potential privacy or security issues

This supports accountability requirements under both PHIPA and PIPEDA.

# Data Security & Hosting

• Data encrypted in transit and at rest

• Health information hosted on Canadian servers

• Regular backups to support data availability and integrity

These safeguards help protect personal and health information against loss, theft, or unauthorized access.

# Forms, Consent & Documentation

• Clinics can create custom forms to collect information and document consent

• Electronic signatures are supported where applicable

• Automatic saving of clinical notes helps preserve accurate records

These tools support consent, transparency, and proper record-keeping.

# Clinic Responsibilities Beyond the Software

While Colib provides a secure platform, privacy compliance ultimately remains the clinic’s responsibility.

Ontario clinics should also ensure they have appropriate internal policies and procedures in place.

# Written Privacy Practices

Under PHIPA, clinics must maintain a written description of their information practices, including:

• How personal information is collected, used, and disclosed

• How individuals can access or request corrections to their records

• How privacy complaints are handled

Colib’s Privacy Policy describes Colib’s own information-handling practices and can be consulted here:
=>  https://www.colib.io/privacypolicy

# Privacy Contact Person

Clinics should designate a person responsible for:

• Overseeing privacy compliance

• Responding to access and correction requests

• Handling privacy questions or complaints

# Consent Management

Clinics must ensure consent is obtained where required and that staff understand when implied versus express consent applies under PHIPA.

# PHIPA, PIPEDA, and Colib’s Legal Framework

Colib operates under clearly defined contractual and legal terms, including its Terms of Service, available here:
? https://www.colib.io/terms

For most Ontario clinics:

• PHIPA governs personal health information used for care

• PIPEDA may apply to non-health personal information and commercial activities

Using a platform like Colib that emphasizes access control, security, accountability, and transparency helps clinics meet the expectations of both laws.

# Key Takeaways

• Ontario clinics must comply with PHIPA and, in some cases, PIPEDA

• Clinics are responsible for safeguarding personal and health information

• Colib provides security features such as 2FA, IP restrictions, encryption, access controls, and audit logs

• Written policies, consent practices, and a designated privacy contact are essential

# Questions?

If you have questions about how Colib supports privacy compliance or need clarification on privacy-related features, please contact support@colib.io.