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How to Manage a Privacy Breach in Your Canadian Practice

How to Manage a Privacy Breach in Your Canadian Practice

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How to Manage a Privacy Breach in Your Canadian Practice Workshop

Have you ever heard about a privacy breach at another practice and thought…

“I hope that never happens to us.”

The reality is — privacy breaches can happen in any healthcare practice, regardless of size, specialty, or technology. Whether it’s a misdirected fax, unauthorized access to a chart, lost device, or cyber incident, breaches are not a matter of if — but when.

What makes the difference is how prepared you are to respond.

I’m tickled pink to  partner with Kayla Das to deliver a live virtual workshop designed to provide practical, step-by-step guidance for Canadian healthcare practices. Kayla Das B.Rec, BSW, MSW, RSW is a trusted Business Coach For Therapists and Counsellors.

Live Virtual Workshop

How to Manage a Privacy Breach in Your Canadian Practice

In this interactive on-line session, we’ll walk you through what to do when a privacy breach occurs — before you ever have to face one in real time.

This workshop is ideal for:

  • Canadian clinic managers
  • Privacy officers
  • Practice owners
  • Social workers, counsellors, and mental health leaders
  • Clinical supervisors and consultants

If you are responsible for protecting patient information, this training will help you strengthen your breach response readiness.

What We’ll Cover

Participants will learn:

  • The difference — and overlap — between confidentiality and privacy
  • Legislative, regulatory, and professional practice requirements across Canada
  • Why privacy breaches are a significant risk you should prepare for
  • How to recognize when a breach has occurred
  • The 4-Step Response Plan for managing a privacy breach
  • Practical steps to prevent breaches before they happen
    … and more

 

Important for Ontario Practitioners

Ontario health information custodians (practice owners) are required to submit annual privacy breach statistics to the Ontario  Information and Privacy Commissioner by March 1 each year.

If you’re unsure what must be reported — or how to prepare — this workshop will address those requirements.

 Workshop Details

Date: Tuesday February 24, 2026
Time: 9:00 AM PST / 12:00 PM EST / 10 AM MT
Length: Approximately 90 minutes

Bonus Benefits

✔️ Replay access available until March 10, 2026
✔️ Certificate of Attendance available for live participants (may support continuing education credits)

Privacy breaches are stressful — but managing them doesn’t have to be overwhelming when you have a plan.

We hope you’ll join us for this practical, supportive session designed to help you protect your patients, your practice, and your professional reputation.

Data Privacy Day 2026 Resources For You!

Data Privacy Day 2026 Resources For You!

Data Privacy Day 2026 Resources for You!

Data Privacy Day is an internationally recognized day dedicated to creating awareness about the importance of privacy and protecting personal information.

That means a lot to me and I think it means a lot to you, too. I think it is important that we give our patients and clients the gift of privacy. And that we have the right tools and resources for our employees to make good privacy and security decisions in our businesses.

Information Managers Ltd. is a Data Privacy Champion!

Data Privacy Week Champion badge 2024

As a DPD Champion, Information Managers recognizes and supports the principle that organizations, businesses, and government all share the responsibility to be conscientious stewards of data by respecting privacy, safeguarding data, and enabling trust.

Each of us is responsible to manage our name and our identity. When you share your personal information, you have the right and responsibility to ask the person or business why they need the information and how they will protect your personal information.
Jean L. Eaton

Your Practical Privacy Coach, Information Managers Ltd.

Data Privacy Day Resources

5 Steps To Prevent Employee Snooping

SAY NO TO SNOOPING!

If an individual affiliate knowingly breaches the privacy and security of health information, and the custodian can demonstrate that reasonable safeguards (including privacy awareness training) were in place, the individual affiliate can be charged under the Health Information Act. Fines of up to $50,000 may be applied to the individual, in addition to other sanctions from their employers and/or their professional regulatory colleges where applicable (HIA s.107).

What Is Snooping?

Looking at someone’s personal information without having an authorized purpose to access that information to do your job is known as ‘snooping’.

Even when you are “just looking” at personal information but don’t share that information with anyone else, this is still a privacy breach.

It is illegal.

Snooping incidents are on the rise and can cost you time, money, heartache, and headache in your practice.

When there is an offence under the privacy legislation like the Health Information Act, there may be an investigation, charges and court appearances, fines, penalties, and loss of employment.

Snooping is entirely preventable.

How Can You Prevent Employee Snooping?

Let’s take a look at the pro-active steps that you can take today to prevent employee snooping.

Download the Practice Management Success Tip 5 Steps to Prevent Employee Snooping

The Practice Management Success Tip, 5 Steps to Prevent Employee Snooping, will help you

  • Take 5 practical steps to prevent employee snooping.
  • Provide clarity about what is considered a privacy breach.
  • Contribute to the health information privacy compliance in your healthcare practice.

Get 5 Steps to Prevent Employee Snooping HERE!

Protect Your Organization and Your Patients With a Privacy Awareness Quiz

Equip your staff with the information they need to confidently and correctly handle personal health information.

Healthcare businesses need privacy awareness training to support key policies and procedures, and risk management programs need a privacy awareness training program.

Reasonable Safeguards

As an employer and healthcare provider, you are responsible to provide training to all of your employees about privacy awareness.

If you don’t provide the training, or if the employees don’t understand the policies and there is a privacy breach, then the healthcare provider is more likely to be held accountable under the legislation and face penalties, including fines and even prison!

Patients value the privacy and security of their information.

Healthcare providers and clinic managers value privacy and security, and they value not having adverse results as a lack of compliance or patient safety issues.

If patients don’t feel that the healthcare provider will keep their information confidential and secure, patients may choose not to share their information, which may impact their healthcare and treatment.

When we are privacy aware, we can better respond to patients’ questions and build their trust in the quality of services that we provide.

Download the Privacy Awareness Quiz to use today to train your employees and protect your patients’ health information.

Download the Privacy Awareness Quiz

Privacy Breach Nugget: When Patient “Success Stories” Become a Privacy Breach

Privacy Breach Nugget: When Patient “Success Stories” Become a Privacy Breach

​When Patient “Success Stories” Become a Privacy Breach

Privacy Breach Nugget

Ever wonder how privacy breaches happen—and what you can do to stop them? Privacy Breach Nuggets takes real cases and turns them into practical lessons for privacy officers, clinics, and healthcare practices. Let’s unpack today’s case and explore what went wrong, what worked, and how you can apply these insights to protect patient information.

What Happened

Cadia Healthcare Facilities, which is a rehabilitation, skilled nursing, and long-term care services provider with 5 locations located in Delaware, US.

Cadia posted patient names, photographs, and detailed health information on its public-facing website as part of a marketing campaign featuring patient “success stories.” These disclosures were made without obtaining valid written authorization from the patients whose information appeared on the website.

4 Step Privacy Breach Response

Cadia’s management of the privacy breach can be examined using the 4 Step Response Plan framework.

Step 1 – Spot and Stop

Cadia had procedures that required employees to obtain a written consent from patients before sharing their testimonials. Despite this, the Office of Civil Rights (OCR) received a complaint in September 2021 alleging that patient information had been disclosed without authorization.

OCR’s investigation ultimately confirmed that the protected health information (PHI) of 150 patients had been disclosed without proper authorization. Cadia was formally notified of these findings in February 2022.

Step 2 – Investigate

Cadia conducted an internal investigation and on March 2022 removed all the success stories from their social media and website and ended the marketing campaign.

However, during this process, the organization deleted the content before confirming which patients had valid written consent on file, making it more difficult to accurately determine the full scope of unauthorized disclosures.

Step 3 – Notify

Cadia initially failed to notify affected patients of the privacy breach, as required. Notification obligations were later addressed as part of the enforcement process. A public notice regarding the breach can now be found on the Cadia website.

Step 4 – Prevent the Breach from Happening Again

According to the OCR settlement details:

  • Cadia agreed to pay a $182,000 USD penalty
  • A Corrective Action Plan (CAP) was imposed, including two years of OCR monitoring and reporting
  • Cadia failed to properly implement its existing administrative privacy policies
  • Cadia is required to:
    • Revise its privacy policies and procedures
    • Provide privacy training to all staff, including marketing personnel
    • Implement stronger authorization processes before using patient information for marketing
  • Cadia must now notify all affected individuals whose PHI was disclosed without authorization

 

Website and Social Media Tips

Custodians are responsible for ensuring that patients’ health information is collected, used, and disclosed in compliance with health privacy legislation, such as Alberta’s Health Information Act (HIA) and Ontario’s Personal Health Information Protection Act (PHIPA).

It’s also important to ensure your practices align with professional college standards related to advertising, professionalism, and confidentiality.

Here are key questions to include in your website and social media compliance checklist before collecting or using patient testimonials:

  • What is your clinic’s approval process before content is posted online?
  • Has the patient provided written consent for their information to be used?
    • If a photograph is included, does the consent explicitly authorize the use of images?
  • Who authorizes the content before it is published?
    • For example: the healthcare provider, lead custodian, social media lead, or privacy officer?
  • Before posting, has the content been reviewed for compliance with:
    • Health privacy legislation?
    • Professional college standards?
  • Does your marketing vendor understand your privacy obligations?
    • Do you have a written agreement in place requiring the vendor to protect the confidentiality of personal health information?

Also See

Is your website secure? Take the Website Self-Assessment from Elevated Business Solutions.

Do you have a website for your healthcare practice in Ontario? PHIPA Website Guide from Elevated Business Solutions will help you.

Take-Aways

The Cadia case is a reminder that policies alone are not enough. Clinics must ensure that privacy requirements are understood, followed in practice, and applied consistently across all teams, including marketing and external vendors. Taking the time to review your website and social media practices now can help prevent a costly and public privacy breach later.

You May Also Be Interested In

Medical Secretary Fined for Unauthorized Access And Disclosure to Health Information

3rd Largest Fine Ever Under the HIA

References

Cadia Healthcare Facilities. Notice of Success Story Incident. https://cadiahealthcare.com/wp-content/uploads/2025/06/Cadia_Notice-1.pdf

Health and Human Services. HHS’ Office for Civil Rights Settles HIPAA Investigation of Cadia Healthcare Facilities for Disclosure of Patients’ Protected Health Information. 2025Sept30. https://www.hhs.gov/press-room/ocr-settles-hipaa-with-cadia-healthcare-facilities.html

Help Me With HIPAA. Did Anyone Even Ask If It Was OK? – Ep 531 podcast. 2025Oct17 https://helpmewithhipaa.com/did-anyone-even-ask-if-it-was-ok-ep-531

Build a Strong Privacy Management Program for Your Clinic With These 5 Critical Modules

Build a Strong Privacy Management Program for Your Clinic With These 5 Critical Modules

Struggling to Learn Your Role As A Privacy Officer?

In many small healthcare practices, the privacy officer is also the clinic manager, healthcare provider, IT technician, or business owner. It’s no surprise that new privacy officers feel overwhelmed trying to balance competing responsibilities.

Without a clear plan, you may find that you

  • Panic when a patient asks for their information for access or correction.
  • Scramble when new employees and healthcare providers join your clinic . . .and suddenly realize that you never got around to providing privacy and cybersecurity awareness training.
  • Hope that your practice will not be tapped on the shoulder for a practice review by your college or the OIPC.
  • Ignore privacy breach and hope no one else notices.
  • Avoid difficult decisions with your owners / staff who insist on doing things their way – even when it is not privacy compliant.
  • Never get ‘review privacy impact assessment’ and ‘review privacy policies and procedures’ off of your to-do list.
  • Avoid discussing privacy and security with your EMR and computer networks managed service providers because you are unsure of what questions to ask and what types of answers you should receive.

If you don’t have a written privacy management program and action plan, you are missing the systems that prevent small issues from becoming privacy and security incidents.

The good news? Organizations with an active privacy officer and privacy management program are less likely to experience breaches and report better staff engagement and patient trust.

Privacy Is Good For Business

Strong privacy practices aren’t just about legal compliance. Policies, procedures, and systems improve communication, reduce risk, and support better decision-making.

A practical privacy management program creates accountability for the collection, use, and disclosure of health information, while demonstrating compliance to regulators and professional colleges.

Based on my experience, the five critical modules of a privacy management program are:

  1. Know Your Obligations
  2. Train
  3. Privacy Breach Management
  4. Document your Privacy Management Program
  5. Access and Disclosure

Module 1—Know your Obligations

Accountability starts with your healthcare provider(s)—also known as “custodians.” They are legally responsible for the privacy, confidentiality, and security of personal health information (PHI).

Custodians can delegate day-to-day tasks to a privacy officer, often the clinic or practice manager in smaller settings. Business owners also have obligations for employee and customer information. Together, the healthcare provider, business owner, and privacy officer form a trifecta of authority responsible for privacy compliance.

Knowing your obligations means:

  • Establishing clear roles and accountability
  • Identifying all types of personal and health information in your practice
  • Understanding how privacy legislation applies to your operations

Training for custodians and privacy officers is often required to build confidence and competence in these responsibilities.

Module 2 – Training

Privacy training is essential and must be consistent across your organization. Every staff member—new and experienced—should complete privacy awareness and cybersecurity training, and you should document attendance.

Effective training includes both formal and informal opportunities:

  • Formal: orientation programs, annual refreshers, and documented privacy awareness training
  • Informal: short reminders in staff meetings, activities tied to events like Data Privacy Day or Cybersecurity Awareness Month

Don’t overlook staff moving into new roles—promotions are an ideal time for targeted training about new responsibilities, such as authorizing users or supervising others.

Module 3 – Privacy Breach Management Plan

Every practice needs a written privacy breach management procedure. The privacy officer should ensure staff know how to recognize and report a breach, and custodians must be notified promptly.

Your plan should cover:

  • How to contain and investigate suspected breaches
  • Sanctions for non-compliance
  • Notification to patients and regulators when required

The privacy officer will manage mandatory privacy breach notification requirements under the health privacy legislation like the Alberta Health Information Act (HIA), Ontario Personal Health and Information Protection Act (PHIPA) and the Personal Information Protection of Electronic Documents Act (PIPEDA) and other province’s legislation.

Module 4 – Document: The Backbone of Privacy Compliance

Privacy training is essential and must be consistent across your organization. Every staff member—new and experienced—should complete privacy awareness and cybersecurity training, and you should document attendance.

Effective training includes both formal and informal opportunities:

  • Formal: orientation programs, annual refreshers, and documented privacy awareness training
  • Informal: short reminders in staff meetings, activities tied to events like Data Privacy Day or Cybersecurity Awareness Month

Don’t overlook staff moving into new roles—promotions are an ideal time for targeted training about new responsibilities, such as authorizing users or supervising others.

Module 5 – Access and Disclosure: Ensuring Patient Rights

Patients and employees have the right to access and correct their information. Release of information (ROI) policies and procedures are essential.

Your ROI plan should:

  • Define clear steps for handling requests
  • Train staff on how to respond appropriately
  • Align with legislation and college standards of practice

Doing this well helps you avoid complaints and breaches, improves efficiency, and strengthens patient trust.

Bringing It All Together

Being a privacy officer doesn’t have to feel overwhelming. With a structured privacy management program built on these five modules, you’ll have the systems to protect patients, support your staff, and strengthen your business.

If you’re a privacy officer in a healthcare practice and want practical strategies you can apply right away, join the upcoming Practical Privacy Officer Strategies training.

Training starts October 9, 2025

Register here https://informationmanagers.ca/ppo

Not sure if this is for you?

Send me an email and ask me! I’m happy to mentor you and help you assess your practice management and privacy compliance priorities.

Do You Want To Be A Confident Healthcare Privacy Officer?

Do You Want To Be A Confident Healthcare Privacy Officer?

Understanding the Role: What Is a Privacy Officer?

A privacy officer is a key employee in a healthcare organization who is named by the healthcare provider (custodian) and assigned the responsibility to oversee all activities related to the implementation of, and adherence to, the organization’s privacy practices, and to ensure operational procedures are in compliance with relevant privacy laws. The Privacy Officer monitors employees and systems about how information is collected, used, and disclosed and access to identifying information.

A privacy officer may be known by other titles like privacy compliance officer or a security officer.

If your healthcare business involves the collection, use, and disclosure of your clients’ and patients’ personal health information, a privacy officer is necessary in order to meet legislated requirements.

Consequences of Operating Without a Privacy Officer

Healthcare practices without a privacy officer often experience confusion about how patients’ personal health information should be collected, used, and disclosed. Patients may complain about lack of access to their personal health information. Without a named privacy officer to assume the responsibility to implement and monitor reasonable administrative, technical, and physical safeguards you are more likely to experience privacy and security incidents, privacy breaches, investigations, fines, and charges under the privacy legislation!

Case Studies: Real-world Implications of Privacy Officer Absence

In 2019, the British Columbia Office of the Information and Privacy Commissioner (OIPC) conducted a privacy audit of 22 medical clinics. OIPC auditors examined 22 clinics and found gaps in privacy management programs at several clinics, including the absence of a designated privacy officer, a lack of funding and resources for privacy and a failure to ensure that privacy practices keep up with technological advances.

Here’s another example. A complaint was made against a medical clinic with an employee suspected of accessing health information for an unauthorized purpose. The Alberta OIPC investigated and revealed confusion around the roles and responsibilities of privacy compliance among the custodians and the privacy officer. The OIPC determined that the custodian was in contravention of the regulation which requires custodians to ensure that their affiliates are aware of and adhere to the all of the custodian’s administrative, technical, and physical safeguards with respect to health information. 

Say No to Snooping: The Need for Privacy Enforcement

Employees are not aware of privacy requirements and engage in snooping into personal health information. Consequences of employee snooping include firing, charges under the Health Information Act and court ordered fines, jail time, probation, community service and more.

say not so snooping animation of thief taking papers from folder

Roles and Responsibilities of a Healthcare Privacy Officer

So, what does a privacy officer do? The roles and responsibilities of a privacy officer in a typical healthcare practices include the following:

  • Identify privacy compliance issues for the business.
  • Ensure privacy and security policies and procedures are developed and keep them up to date.
  • Ensure that everyone working at your clinic and your vendors are aware of their privacy obligations.
  • Monitor your clinic’s ongoing compliance with privacy legislation like the Health Information Act (HIA) in Alberta.
  • Provide advice and interpretation of related legislation for the business.
  • Respond to requests for access and corrections to personal information.
  • Ensure the security and protection of personal information in the custody or control of the business.
  • Act as the primary point of privacy and access contact for staff, patients, vendors, regulators and other stakeholders.
 

Introducing Practical Privacy Office Strategies Training

I want to help you become a confident healthcare privacy officer. And a guide (or a Jeannie ) to help you is a good thing.

Practical Privacy Officer Strategies will help you to assess your current PIA and privacy management program and plan your privacy compliance activities for the next year!

Practical Privacy Officer Strategies will help you to assess your current PIA and privacy management program and plan your privacy compliance activities for the next year!
5 Modules with Live 1-hour training and on-line mentoring will help you to build systems to monitor the routine tasks that will protect privacy and alert you to potential problems before they become privacy and security incidents.
 
How the training will be delivered:
  • Pre-recorded core training in each of the 5 modules. You watch the 1 hour video before the live coaching call.
  • Live 1 hour coaching call with practical case study, discussion, and accountability in each of the 5 modules.
  • Actionable plan with templates, tools, and resources to use what you learned.
  • Every module includes both WHY you need the information and HOW you should use the information.
 
Find Out More!