Privacy: PIPEDA Compliance for Clinics in Canada

Created by Thibault Breboin, Modified on Wed, 4 Feb at 5:50 AM by Thibault Breboin

Privacy: PIPEDA Compliance for Clinics in Canada

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

For clinics located in provinces or territories without substantially similar private-sector privacy legislation, the primary governing law is PIPEDA (Personal Information Protection and Electronic Documents Act).

This article provides an overview of PIPEDA’s requirements as they apply to healthcare clinics and explains how Colib supports clinics in implementing secure, privacy-compliant data management practices. This content is provided for informational purposes only and does not constitute legal advice.


Provincial Privacy Compliance Guides

In addition to this national overview, Colib provides province-specific compliance guidance where applicable. Refer to the relevant article for your province:

These guides walk through the applicable provincial laws (PHIPA, Health Information Act, Loi 25, PIPA BC) and how Colib’s security and privacy controls map to your compliance requirements.


Privacy Laws Applicable to Clinics in Canada

PIPEDA — Canada’s Federal Private-Sector Privacy Law

PIPEDA applies to private-sector organizations across Canada that collect, use, or disclose personal information in the course of commercial activities.

In the healthcare context, PIPEDA typically applies to clinics operating in provinces and territories where no substantially similar provincial private-sector privacy law exists, or in situations involving:

  • interprovincial or cross-border data flows;

  • interactions with federally regulated organizations;

  • commercial activities that fall under federal jurisdiction.

Under PIPEDA, clinics are accountable for how personal information — including personal health information — is handled throughout its lifecycle.


Core Privacy Principles Under PIPEDA

PIPEDA is based on ten Fair Information Principles, which form the foundation of privacy compliance for clinics, including:

  • Accountability: clinics must designate responsibility for privacy compliance and implement appropriate policies and practices.

  • Identifying purposes: the purposes for collecting personal information must be identified before or at the time of collection.

  • Consent: meaningful consent must be obtained for the collection, use, and disclosure of personal information, subject to limited exceptions.

  • Limiting collection: only information necessary for identified purposes may be collected.

  • Limiting use, disclosure, and retention: information must only be used or disclosed for authorized purposes and retained only as long as necessary.

  • Accuracy: information must be accurate, complete, and up to date.

  • Safeguards: appropriate administrative, technical, and physical safeguards must protect personal information.

  • Openness: clinics must be transparent about their privacy practices.

  • Individual access: individuals have the right to access and request corrections to their personal information.

  • Challenging compliance: individuals must be able to raise privacy concerns or complaints.


How Colib Supports PIPEDA Compliance

Colib is designed to help clinics implement reasonable safeguards and operational controls that align with PIPEDA’s expectations for privacy protection, security, and accountability.

Access Controls and Security Measures

Colib provides clinics with tools to secure and manage access to personal and health information, including:

  • Individual user accounts with unique credentials

  • Granular, role-based access controls defined by the clinic

  • Two-factor authentication (2FA) for practitioners and for clients using the client portal

  • IP address restrictions, when necessary, to limit access to approved networks or locations

These measures help reduce the risk of unauthorized access and support PIPEDA’s safeguard requirements.


Accountability and Auditability

  • Detailed activity logs record when personal information is accessed or modified, and by whom

  • Clinic owners can review these logs to support internal oversight, investigations, and accountability

These features support PIPEDA’s accountability and monitoring expectations.


Data Hosting and Protection

  • Data encrypted in transit and at rest

  • Personal and health information hosted on Canadian servers

  • Regular backups to ensure data availability and integrity

  • Logical separation between production, testing, and development environments

These safeguards help protect personal information against loss, unauthorized access, or disclosure.


Consent, Forms, and Documentation

  • Customizable electronic forms allow clinics to clearly inform patients about how their personal information is collected and used

  • Consent can be documented as part of clinical and administrative workflows

  • Real-time and automatic data saving reduces the risk of accidental data loss

These tools support PIPEDA’s consent and transparency requirements.


Organizational Responsibilities Under PIPEDA

While Colib provides a secure technical platform, privacy compliance under PIPEDA remains the responsibility of the clinic.

Clinics should ensure that they:

  • maintain written privacy policies and practices;

  • designate a privacy contact or responsible person;

  • respond to access and correction requests within required timeframes;

  • manage and document privacy complaints and incidents.


Privacy Breach Management

Under PIPEDA, organizations must report breaches of security safeguards involving personal information that pose a real risk of significant harm.

This includes obligations to:

  • notify affected individuals;

  • report the breach to the Office of the Privacy Commissioner of Canada;

  • maintain records of all breaches.

Colib includes preventive safeguards such as encryption, access controls, and activity logging. However, assessing incidents and fulfilling reporting and notification obligations remain the clinic’s responsibility.


Clinic Responsibilities and Colib’s Role

Colib acts as a technology service provider supporting clinics in the secure management of personal and health information.

What Colib Provides

  • A secure, access-controlled platform

  • Security and privacy features aligned with PIPEDA expectations

  • Tools supporting consent documentation and transparency

  • Canadian data hosting and encryption

Colib’s information-handling practices are described in its Privacy Policy:
https://www.colib.io/privacypolicy


What Clinics Remain Responsible For

  • Determining the purposes for collecting and using personal information

  • Establishing and maintaining privacy policies and procedures

  • Obtaining valid consent in accordance with PIPEDA

  • Managing privacy incidents, complaints, and access requests

Colib’s contractual framework and responsibilities are outlined in its Terms of Service:
https://www.colib.io/terms

Colib provides the technical foundation, while regulatory accountability remains with the clinic.


Key Takeaways

  • PIPEDA governs privacy compliance for clinics in many parts of Canada.

  • Clinicians remain responsible for the protection of personal and health information.

  • Colib provides access controls, security safeguards, auditability, and Canadian data hosting to support compliance.

  • Full compliance requires both technical safeguards and organizational privacy practices.


Questions?

If you have questions about PIPEDA compliance or how Colib supports privacy-compliant clinic operations across Canada, please contact support@colib.io.

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