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Privacy, Health and Security

Health Information and PHIPA Statement

How PSW Pro relates to Ontario’s PHIPA and your responsibilities for personal health information.

1. PSW Pro's Role

PSW Pro is an administrative technology platform. It provides tools for scheduling, client records, care notes, timesheets, invoicing, and other business-management functions. PSW Pro is not a healthcare provider, health information custodian in every situation, or a substitute for professional clinical judgment.

Depending on how the platform is used, the information stored in PSW Pro may include personal health information. This statement explains how PSW Pro relates to Ontario's Personal Health Information Protection Act, 2004 (PHIPA) and the responsibilities of subscribers and authorized users.

2. Potential Processing of Personal Health Information

Customer Data entered into PSW Pro may include:

  • Client names, contact details, and care-level information;
  • Care notes describing services provided, observations, and incidents;
  • Visit logs, schedules, and shift assignments;
  • Health-related notes or observations recorded by care providers;
  • Other information that may qualify as personal health information under PHIPA.

Whether information entered into the platform constitutes personal health information depends on the context, the identity of the person who entered it, and the purpose for which it was collected.

3. Subscriber Responsibilities for Lawful Authority and Consent

Each subscriber and authorized user is responsible for:

  • Determining whether the information they enter is personal health information;
  • Establishing lawful authority for its collection, use, and disclosure;
  • Obtaining and documenting any required consent from the client or their substitute decision-maker;
  • Complying with PHIPA, other applicable privacy legislation, and professional obligations.

PSW Pro does not determine whether a user is a health information custodian, an agent of a custodian, or another regulated care provider. That determination depends on the subscriber's role, organization, and circumstances.

4. Health Information Custodians and Their Agents

Under PHIPA, a health information custodian is generally responsible for personal health information in their custody or control. Custodians may delegate certain functions to agents who act on their behalf.

If you are a health information custodian or an agent of a custodian, you remain responsible for:

  • Establishing legal authority for collection, use, and disclosure of health information;
  • Obtaining and recording consent;
  • Limiting access to authorized individuals;
  • Responding to access and correction requests;
  • Maintaining appropriate records;
  • Managing retention requirements;
  • Investigating and reporting privacy breaches;
  • Configuring roles and permissions within the platform;
  • Meeting all professional and regulatory requirements.

5. PSW Pro Acting According to Customer Instructions

PSW Pro processes Customer Data according to the instructions of the subscriber and authorized users. PSW Pro does not independently make decisions about client care, treatment, medication, or clinical appropriateness.

PSW Pro's role is to provide the technology platform. The subscriber directs how the platform is configured and used, subject to our Terms of Service and Privacy Policy.

6. Access Controls and Assigned Client Records

PSW Pro uses row-level security and role-based access controls to help ensure that users only access records they are authorized to view. However, technical access controls do not replace the subscriber's responsibility to configure roles, permissions, and assignments appropriately.

Organization administrators must ensure that workers are only assigned to clients and records that fall within their authorized duties.

7. Care-Note Responsibilities

The user who creates or approves a care note is responsible for ensuring that it is accurate, complete, objective, timely, professionally appropriate, and compliant with applicable legal and professional requirements.

PSW Pro does not independently verify that care notes accurately describe events or meet clinical documentation standards.

8. Accuracy and Correction

Users are responsible for reviewing and correcting errors in records they create. If a record contains an error, it must be corrected using an appropriate and legally compliant correction procedure.

Requests to correct personal health information should be directed to the organization that controls the information. PSW Pro will cooperate with reasonable correction requests from authorized administrators.

9. Privacy Requests

Individuals may have rights under PHIPA or other privacy legislation to request access to or correction of their personal health information. These requests should generally be directed to the health information custodian or organization that collected the information.

PSW Pro will cooperate with reasonable requests from authorized administrators to export or correct data within the platform. For privacy requests involving PSW Pro's own practices, contact our Privacy Officer at support@pswpro.ca.

10. Retention and Data Exports

Subscribers are responsible for determining and meeting retention requirements applicable to their records. PSW Pro provides tools that may assist with data export, but the subscriber remains responsible for ensuring that retention and deletion obligations are met.

For more information, see our Data Retention and Account Deletion Policy.

11. Privacy Incidents

If a privacy breach or suspected breach occurs, the subscriber is responsible for investigating, documenting, and reporting as required under PHIPA or other applicable legislation.

PSW Pro will cooperate with reasonable investigations and may take action to protect the platform if a breach is suspected. Contact support@pswpro.ca promptly if you suspect a privacy incident involving the platform.

12. Subprocessors and Cross-Border Processing

PSW Pro uses third-party service providers that may process data on our behalf. Some providers may process data outside Canada, which may subject the data to the laws of another jurisdiction.

For more information, see our Third-Party Providers and Subprocessors page.

13. No Automatic PHIPA Compliance

Using PSW Pro does not automatically make a person or organization compliant with PHIPA. Compliance depends on how the platform is configured and used, as well as the subscriber's policies, training, decisions, and circumstances.

PSW Pro provides privacy-conscious tools, but does not guarantee that any subscriber will meet all PHIPA obligations. Each subscriber must obtain their own legal and professional advice to determine compliance requirements.

14. No Clinical or Medical Decision-Making

PSW Pro does not make clinical or medical decisions. The platform does not diagnose conditions, recommend treatments, or assess clinical appropriateness. All care decisions remain the responsibility of qualified professionals.

See our Disclaimer for important limitations.

15. Not for Emergency Use

PSW Pro is not an emergency communication, monitoring, or response system. If someone may be in danger or requires urgent medical assistance, call 911 or the appropriate local emergency service immediately.

16. Contacting the Privacy Officer

For questions about this statement, privacy practices, or PHIPA-related inquiries, contact:

Privacy Officer
PSW Pro
Email: support@pswpro.ca
Website: https://pswpro.ca

Last updated: August 16, 2026

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