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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.

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

Privacy Breach Nugget: Why Documentation Matters in Privacy Breach Investigations

Privacy Breach Nugget: Why Documentation Matters in Privacy Breach Investigations

Investigation Tips Following the NWT Health Authority Incident

When employees make mistakes that result in a privacy breach, the custodian is held responsible to ensure that appropriate investigations are performed. This includes appropriate documentation of the privacy breach incident and sanctions when indicated.

The NWT Information and Privacy Commissioner (IPC) opened an investigation into the Northwest Territories Health and Social Services Authority (NTHSSA) after a reported privacy breach in 2024. This review aimed to assess whether the health authority had adequate safeguards in place to investigate and prevent similar future incidents.

Privacy Breach Nuggets takes real cases and turns them into practical lessons for privacy officers, clinics, and healthcare practices. Let’s dive into what went wrong, what worked, and how you can apply these insights to strengthen your privacy program.

What Happened

In April 2024, a patient filed a complaint with the nurse-in-charge at a health centre in the Northwest Territories. The complaint alleged that a clerk had inappropriately shared the patient’s personal health information with a family member during a casual conversation.

The nurse-in-charge apologized to the patient and escalated the issue to the regional manager. The clerk denied disclosing the health information, but the health authority concluded the incident had indeed occurred.

The Commissioner emphasized that there was no ill intent, stating:

“The interaction between the clerk and the sister was spontaneous and indicates a simple lapse in judgment.”

Managing the Breach

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

Step 1 – Spot and Stop

The privacy breach was identified by the patient and reported to the nurse in charge and escalated to the regional manager.

Step 2 – Investigate

An investigation was initiated. While the clerk denied the allegation, the health authority determined a breach had occurred.

However, the Commissioner noted a serious concern: the investigation was poorly documented. If notes were taken, they could not be located or produced during the review.

Step 3 – Notify

The patient and NTHSSA (the custodian) was aware of the breach. No further notification was required.

Step 4 – Prevent the Breach from Happening Again

The health authority directed the clerk to:

  • Complete updated privacy training
  • Review the oath of office
  • Review patient confidentiality policies

No further disciplinary action was taken.

Commissioner’s Investigation

The IPC made several key recommendations:

  • Equip investigators: Ensure staff who investigate privacy breaches are properly trained and supported to conduct effective, timely, and well-documented investigations.
  • Enforce sanctions: Ensure managers understand the range of disciplinary options available and are aware of their obligation to apply reasonable disciplinary measures when warranted.
  • Annual privacy training: Reinforce the Mandatory Training Policy by ensuring all employees complete refresher privacy training every year.
  • Use real examples: Incorporate this privacy breach as a case study in future privacy training to help employees understand their obligations—at work and outside of work.

Take-Aways

Annual privacy training is not enough.

Training must include real-world, job-relevant examples and emphasize how privacy rules apply in everyday situations.

When employees make mistakes, it’s the custodian’s responsibility to lead an appropriate and well-documented investigation—not just revisit outdated training.

A strong privacy culture includes tools, training, and clarity. Equip your investigators, privacy officers, and managers with the skills they need to respond appropriately.

For more on how to manage privacy-related employee errors, listen to the podcast:

Managing Employees When They Make Mistakes – Episode #105

Need Help Training Your Privacy Team?

Ask me about Practical Privacy Officer Strategies training to strengthen your internal investigation process and build a more resilient workplace.

Reference

NWT IPC File Number: 24-950-6 on April 4, 2025Northwest Territories Health and Social Services Authority (Re), 2025 NTIPC 97 (CanLII), <https://canlii.ca/t/kc0s6>, retrieved on 2025-06-09

You May Also Be Interested In

Medical Secretary Fined for Unauthorized Access And Disclosure to Health Information

3rd Largest Fine Ever Under the HIA