Privacy & Protection of Personal Health Information

Privacy Policy

Carenfly Nursing | Canada

Effective Date: November 11, 2026
Last Updated: November 11, 2026

1. Introduction

Carenfly Inc. (“Carenfly”, “we”, “our” or “us”), operating its nursing and home care services under the brand Carenfly Nursing, is committed to respecting your privacy and protecting your personal information and personal health information.

This Privacy Policy explains how we collect, use, disclose, store, retain and protect information when you visit our website, submit an inquiry, request our services or receive nursing and home care support in Ontario, Canada.

We handle personal information responsibly and in accordance with applicable privacy laws, including Ontario’s Personal Health Information Protection Act, 2004 (PHIPA), where applicable, and other applicable privacy legislation.

Our approach is based on confidentiality, responsible information management, appropriate access controls and respect for individual privacy rights.

2. Information We Collect

Depending on the services requested and your interactions with Carenfly Nursing, we may collect the following categories of information:

2.1 Personal and Contact Information

  • Full name

  • Residential or service address

  • Email address

  • Telephone number

  • Preferred method of communication

  • Emergency contact information

  • Information about an authorized representative, where applicable

2.2 Personal Health Information

When necessary for assessing, arranging, coordinating or providing care, we may collect personal health information such as:

  • Relevant medical history and health conditions

  • Current care needs and support requirements

  • Mobility and daily living assistance needs

  • Relevant clinical assessments and care instructions

  • Medication-related information, where necessary for the services provided

  • Nursing and home care records

  • Relevant information provided by authorized healthcare professionals

We aim to collect only information that is reasonably necessary for the identified purpose.

2.3 Service and Administrative Information

We may also collect:

  • Requested care services

  • Preferred service schedules

  • Care coordination and visit information

  • Service agreements and consent records

  • Communications with patients and authorized representatives

  • Billing and payment-related information, where applicable

2.4 Website and Technical Information

When you visit our website, certain technical information may be collected automatically, including:

  • IP address

  • Browser type and device information

  • Website usage information

  • Cookies and similar technologies

  • Pages visited and interaction data

Please refer to our Cookie Policy for additional information about website tracking technologies.

3. How We Collect Information

We may collect information through:

  • Online inquiry and registration forms

  • Direct communication by telephone, email or other communication channels

  • Patient assessments and care coordination processes

  • Information provided by authorized representatives

  • Healthcare professionals or other sources where permitted by applicable law

  • Our website and associated digital services

Where required, we will obtain appropriate consent before collecting personal health information.

4. How We Use Your Information

Carenfly Nursing may use personal information and personal health information for purposes such as:

  • Responding to inquiries and service requests

  • Understanding individual care requirements

  • Assessing and coordinating requested services

  • Arranging appropriate nursing or home care support

  • Communicating with patients and authorized representatives

  • Coordinating visits and care-related activities

  • Maintaining appropriate patient and service records

  • Managing administrative and payment processes

  • Meeting applicable legal, regulatory and professional obligations

  • Managing service quality, safety and operational requirements

  • Responding to questions, concerns or complaints

We do not use personal health information for unrelated purposes without an appropriate legal basis.

5. Consent and Your Choices

We respect your right to make informed decisions about your personal information and personal health information.

Where consent is required, we will seek appropriate consent for the collection, use and disclosure of your information.

Depending on the circumstances and applicable law, consent may be express or implied.

You may have the right to:

  • Ask how your information will be collected and used.

  • Decline certain requests for information, subject to applicable legal requirements.

  • Withdraw or change consent where permitted by law.

  • Place restrictions on certain information-sharing activities where applicable.

  • Ask questions about how your information is handled.

Withdrawing consent may affect our ability to arrange or continue certain services.

6. Disclosure and Sharing of Information

Carenfly Nursing does not disclose personal health information indiscriminately.

Information may be shared when necessary and legally permitted for purposes such as:

6.1 Authorized Care Professionals

Relevant information may be made available to authorized nurses, personal support workers and other assigned care professionals when necessary for their responsibilities.

6.2 Authorized Representatives

Information may be shared with family members, substitute decision-makers or other representatives where the individual has provided appropriate authorization or where disclosure is otherwise permitted or required by law.

6.3 Healthcare Providers

Where appropriate and legally permitted, relevant information may be shared with healthcare providers involved in coordinating or supporting an individual’s care.

6.4 Service Providers

We may use third-party service providers to support our operations, including secure information technology, communication, scheduling, record management and administrative services.

Where these providers handle personal health information, appropriate contractual, confidentiality and security requirements must be established.

6.5 Legal and Regulatory Requirements

Information may be disclosed where required or permitted by applicable laws, regulations, court orders or authorized regulatory processes.

We aim to limit information sharing to what is reasonably necessary for the applicable purpose.

7. Centralized Patient Records Management

Carenfly Nursing follows a centralized patient records management approach.

Patient and service records are managed through systems and processes designated by Carenfly, subject to applicable legal and contractual responsibilities.

Our intended records management practices include:

  • Maintaining organized patient records.

  • Restricting access to authorized individuals.

  • Providing care professionals with access appropriate to their assigned responsibilities.

  • Maintaining relevant service and care documentation.

  • Managing patient information through approved channels.

  • Reviewing access permissions when professional assignments or service relationships change.

Care professionals and contractors are expected to maintain confidentiality and follow applicable information protection requirements when performing services on behalf of Carenfly.

8. Information Security

We recognize the importance of protecting personal information against unauthorized access, loss, misuse, alteration and disclosure.

Carenfly Nursing is committed to implementing appropriate administrative, technical and physical safeguards, taking into account the sensitivity of the information and the nature of our services.

These safeguards may include:

  • Role-based access restrictions.

  • Individual user access permissions.

  • Confidentiality obligations.

  • Secure information handling procedures.

  • Appropriate access monitoring.

  • Secure storage and backup practices.

  • Procedures for responding to suspected privacy incidents.

Access to patient information is intended to be limited to individuals who require

PHIPA & Health Information

Carenfly Nursing | Ontario, Canada

1. Understanding PHIPA

The Personal Health Information Protection Act, 2004 (PHIPA) is Ontario’s legislation governing the collection, use and disclosure of personal health information by health information custodians and their authorized agents.

PHIPA establishes rules designed to protect individuals’ privacy while allowing personal health information to be handled appropriately for healthcare purposes.

Carenfly Nursing recognizes the importance of these protections and is committed to developing responsible information management practices in accordance with applicable Ontario privacy requirements.

2. What Is Personal Health Information?

Personal Health Information (PHI) refers to identifying information about an individual that relates to their physical or mental health, healthcare history, healthcare services or related matters, as defined under PHIPA.

Depending on the services involved, personal health information may include:

  • Medical history and health conditions.

  • Information about physical or mental health.

  • Nursing assessments and care plans.

  • Medication and treatment-related information.

  • Mobility and personal care requirements.

  • Information about healthcare services received.

  • Clinical observations and progress notes.

  • Information identifying healthcare providers involved in an individual’s care.

Personal health information may exist in electronic, paper, verbal or other recorded formats.

3. Health Information Custodians and Authorized Agents

PHIPA identifies certain healthcare professionals, organizations and other entities as Health Information Custodians (HICs).

A Health Information Custodian has legal responsibilities concerning personal health information under its custody or control.

An authorized agent may handle personal health information on behalf of a Health Information Custodian, but only within the scope of their authorized responsibilities and applicable legal requirements.

The legal role of Carenfly Nursing depends on the nature of the services provided, the professional relationships involved and the applicable arrangements governing custody and control of patient records.

Carenfly will establish its privacy responsibilities and contractual arrangements according to its actual operating model and applicable legislation.

4. Collection of Health Information

Personal health information may be collected when reasonably necessary for purposes such as:

  • Understanding an individual’s care requirements.

  • Assessing requested nursing or home care services.

  • Developing or coordinating appropriate care arrangements.

  • Supporting authorized healthcare professionals.

  • Maintaining relevant patient and service records.

  • Meeting applicable legal or professional obligations.

Where required, appropriate consent or another lawful authority must exist before personal health information is collected.

Information may be obtained directly from the individual or, where legally permitted, from an authorized representative or another appropriate source.

We aim to collect only information reasonably necessary for the identified purpose.

5. Use of Health Information

Personal health information may be used for authorized purposes connected with the individual’s care and the administration of relevant services.

Depending on the circumstances, these purposes may include:

  • Reviewing care requirements.

  • Coordinating assigned nursing and home care services.

  • Preparing and maintaining care documentation.

  • Supporting communication among authorized care professionals.

  • Monitoring service delivery and continuity of care.

  • Managing administrative and operational responsibilities.

  • Meeting legal and regulatory obligations.

Personal health information must not be accessed or used merely out of curiosity or for an unrelated personal purpose.

Access and use must be consistent with applicable legal authority and the individual’s privacy rights.

6. Disclosure and Sharing of Health Information

Personal health information may be disclosed only where there is appropriate consent or another legal authority under applicable privacy legislation.

Depending on the circumstances, authorized sharing may involve:

  • Healthcare professionals involved in an individual’s care.

  • Assigned nursing or home care personnel.

  • Authorized family members or representatives.

  • Other healthcare organizations where legally permitted.

  • Regulatory or public authorities where required or permitted by law.

When information is shared, reasonable steps should be taken to ensure that the information is accurate, relevant and limited to what is reasonably necessary for the purpose.

Where express consent is legally required, it must be obtained before the disclosure unless a legal exception applies.

7. Minimum Necessary Information

Carenfly Nursing supports the principle of limiting access to personal health information according to legitimate responsibilities and authorized purposes.

Our intended access management practices include:

  • Assigning individual accounts to authorized personnel.

  • Restricting access according to professional roles and assigned duties.

  • Providing access only to relevant patient information.

  • Reviewing permissions when assignments change.

  • Preventing unauthorized access to patient records.

  • Maintaining appropriate confidentiality obligations.

For example, a care professional should only access the patient information necessary to perform their assigned responsibilities.

Access to one patient’s records does not automatically provide access to other patients’ records.

8. Patient Consent and Substitute Decision-Makers

Consent is an important part of protecting personal health information.

Under PHIPA, where consent is required, it must generally:

  • Be given by the individual or an authorized substitute decision-maker.

  • Be knowledgeable.

  • Relate to the information concerned.

  • Be given without deception or coercion.

Depending on the circumstances, consent may be express or implied, unless express consent is specifically required.

If an individual is not capable of making a particular privacy decision, an authorized substitute decision-maker may be able to provide consent in accordance with applicable legal requirements.

For additional information, please refer to our Patient Consent section.

9. Patient Access and Correction Rights

Individuals may have the right to request access to their personal health information and request corrections to records they believe are inaccurate or incomplete.

These rights are subject to applicable legal requirements and exceptions.

Carenfly Nursing will provide an appropriate process for receiving and reviewing access and correction requests where it has the relevant legal responsibility for the records.

Please refer to our Access & Correction section for further information.

10. Confidentiality Responsibilities of Care Professionals

All individuals authorized to access patient information are expected to respect confidentiality and follow applicable privacy requirements.

Depending on their role and legal relationship with Carenfly, care professionals and contractors may be required to:

  • Access information only for authorized work purposes.

  • Keep patient information confidential.

  • Use approved communication and recordkeeping channels.

  • Avoid sharing patient information with unauthorized individuals.

  • Protect devices and accounts used to access patient records.

  • Report suspected privacy incidents promptly.

  • Follow applicable policies and contractual obligations.

Confidentiality responsibilities continue after an individual’s professional assignment or contractual relationship ends.

11. Privacy Safeguards and Record Protection

Appropriate safeguards are essential to protecting personal health information.

Carenfly Nursing is committed to establishing administrative, technical and physical safeguards appropriate to the sensitivity of the information and the nature of its services.

These may include:

  • Role-based access controls.

  • Individual user authentication.

  • Secure electronic record management.

  • Appropriate encryption and backup arrangements.

  • Access monitoring and recordkeeping.

  • Confidentiality agreements and staff training.

  • Procedures for responding to privacy incidents.

The specific safeguards implemented will depend on the systems and services used by Carenfly Nursing.

12. Questions and Privacy Concerns

If you have questions about how your personal health information is collected, used, disclosed or protected, you may contact:

Carenfly Nursing – Privacy Office
Carenfly Inc.
Toronto, Ontario, Canada

Email: info@carenfly.com

Subject: PHIPA & Health Information Inquiry

You may also contact the Information and Privacy Commissioner of Ontario (IPC) for information about Ontario’s health privacy legislation and your privacy rights.

Website: https://www.ipc.on.ca/


Carenfly Nursing | Respecting Your Privacy. Supporting Your Care.

A service of Carenfly Inc.
Toronto, Ontario, Canada

Patient Consent & Information Sharing

Carenfly Nursing | Ontario, Canada

1. Understanding Patient Consent

At Carenfly Nursing, we respect your right to make informed decisions about your care and your personal health information.

Consent is an important part of protecting your privacy and ensuring that your information is handled appropriately.

Under Ontario’s Personal Health Information Protection Act, 2004 (PHIPA), consent requirements apply to the collection, use and disclosure of personal health information by health information custodians and their authorized agents, where applicable.

Depending on the circumstances, consent may be express or implied, unless express consent is specifically required by law.

2. Consent to Collect Personal Health Information

To understand your care requirements and coordinate appropriate services, certain personal health information may need to be collected.

Depending on the services requested, this information may include:

  • Relevant medical and health history.

  • Current health conditions and care requirements.

  • Mobility and daily living support needs.

  • Relevant medication and treatment information.

  • Nursing assessments and care instructions.

  • Emergency contact and authorized representative information.

We aim to collect only the information reasonably necessary for the identified purpose.

Where required, appropriate consent or another lawful authority must exist before collecting this information.

3. Consent to Use Personal Health Information

Personal health information may be used for authorized purposes related to your care and the administration of relevant services.

These purposes may include:

  • Reviewing your individual care needs.

  • Assessing and coordinating requested services.

  • Preparing and maintaining relevant care records.

  • Supporting continuity of care.

  • Coordinating assigned care professionals.

  • Communicating with authorized individuals involved in your care.

  • Managing service-related administrative responsibilities.

  • Meeting applicable legal and regulatory obligations.

Your information will not be used for unrelated purposes without an appropriate legal authority.

4. Consent to Share Personal Health Information

In certain circumstances, sharing relevant health information may be necessary to coordinate or support your care.

Depending on the circumstances and applicable legal requirements, information may be shared with:

4.1 Assigned Care Professionals

Relevant information may be made available to authorized nurses, personal support workers and other assigned professionals who require it to perform their responsibilities.

4.2 Healthcare Providers

Information may be shared with healthcare providers involved in your care where appropriate consent or another legal authority exists.

4.3 Family Members and Authorized Representatives

Information may be shared with family members, substitute decision-makers or other representatives when you have provided appropriate authorization or disclosure is otherwise permitted or required by law.

4.4 Service and Technology Providers

Certain service providers may process information on behalf of Carenfly to support authorized administrative, scheduling, communication or records management activities.

Appropriate privacy and confidentiality safeguards must be established for these arrangements.

Information will not be shared simply because someone is a family member or acquaintance. An appropriate legal basis must exist for disclosure.

5. Express and Implied Consent

Consent requirements depend on the nature of the information and the intended activity.

Express Consent

Express consent may be provided verbally, in writing or electronically, depending on the circumstances and applicable requirements.

It is generally required in situations where PHIPA specifically requires express consent, including certain disclosures outside the circle of care.

Implied Consent

In certain circumstances, consent may be implied when the requirements of PHIPA are satisfied.

For example, certain healthcare providers may rely on implied consent to share relevant personal health information within the circle of care, provided the legal conditions are met and no restriction or withdrawal of consent applies.

Carenfly Nursing will respect the applicable consent requirements for each situation.

6. Family Members and Substitute Decision-Makers

You may identify an individual who is authorized to receive certain information or assist with decisions concerning your care.

Depending on the circumstances, this may include:

  • A spouse or family member.

  • A legally authorized representative.

  • A substitute decision-maker.

  • A parent or legal guardian, where applicable.

Being a family member does not automatically grant someone access to your personal health information.

Where a substitute decision-maker is involved, their authority will be assessed in accordance with applicable Ontario laws.

7. Your Right to Withdraw or Change Consent

You may have the right to withdraw or change your consent to the collection, use or disclosure of your personal health information, subject to applicable legal requirements.

You can contact Carenfly Nursing to:

  • Change your previous consent instructions.

  • Withdraw consent where permitted by law.

  • Request restrictions on certain information-sharing activities.

  • Ask questions about how your information is being handled.

A withdrawal or change of consent does not automatically reverse actions already lawfully taken before the change.

It may also affect our ability to arrange or continue certain services if the information is necessary for their safe and appropriate delivery.

Certain information may still need to be retained or disclosed where required or permitted by law.

8. Consent for Photographs, Videos and Recordings

Photographs, videos or recordings may sometimes be useful for care-related documentation or other specifically identified purposes.

Any use of photographs or recordings for marketing, promotional materials, testimonials or public communications requires a separate and appropriate authorization where applicable.

Refusing marketing or promotional consent will not, by itself, affect your eligibility for nursing or home care services.

Please refer to our separate Photography & Media Consent document for further information.

9. Consent for Minors and Individuals Requiring Assistance

Where services involve minors or individuals who may be incapable of making a particular decision, consent will be handled in accordance with applicable Ontario capacity and privacy laws.

Depending on the circumstances, consent may be provided by the individual or an authorized substitute decision-maker.

The authority of a representative may need to be verified before information is collected, used or disclosed based on their instructions.

10. How to Provide or Update Your Consent

Where consent is required, Carenfly Nursing will provide appropriate information about the purpose and scope of the requested consent.

Depending on the process involved, consent may be documented through:

  • Written consent forms.

  • Secure electronic forms.

  • Verbal consent, where legally appropriate.

  • Other legally recognized methods.

You may contact our Privacy Office if you wish to ask questions, update your consent instructions or request further clarification.

11. Questions About Patient Consent

If you have questions about consent, information sharing or your privacy rights, please contact:

Carenfly Nursing – Privacy Office
Carenfly Inc.
Toronto, Ontario, Canada

Email: info@carenfly.com

Subject: Patient Consent Inquiry – Carenfly Nursing

Please avoid sending detailed medical records or sensitive health information through ordinary email unless a secure communication method has been provided.

You may also consult the Information and Privacy Commissioner of Ontario (IPC) for information about your rights under PHIPA.

Website: https://www.ipc.on.ca/


Carenfly Nursing | Your Care. Your Privacy. Your Choices.

A service of Carenfly Inc.
Toronto, Ontario, Canada

Access & Correction of Health Records

Carenfly Nursing | Ontario, Canada

1. Your Right to Access Your Health Records

Carenfly Nursing respects your right to access personal health information in accordance with applicable Ontario privacy legislation, including the Personal Health Information Protection Act, 2004 (PHIPA), where applicable.

Depending on the legal responsibility for the records, you may have the right to request access to personal health information held by or under the custody or control of the relevant Health Information Custodian.

This may include information such as:

  • Personal health information maintained in your patient record.
  • Relevant nursing and care assessments.
  • Care plans and service documentation.
  • Relevant clinical observations and progress notes.
  • Records of healthcare services provided.
  • Other personal health information relating to your care.

Certain legal exceptions may apply to access requests.

2. How to Request Access to Your Records

If you would like to access your personal health information, you may submit a written request to Carenfly Nursing.

Your request should include:

  • Your full name.
  • Your contact information.
  • Sufficient information to identify your patient record.
  • The type of information or records you wish to access.
  • The relevant date range, if known.
  • Your preferred method of receiving the information.

We may request reasonable identity verification before providing access to confidential records.

If someone is submitting a request on your behalf, we may also need documentation confirming their legal authority to act for you.

3. Requesting a Correction

You may request a correction if you believe that personal health information in your record is inaccurate or incomplete.

Examples may include:

  • Incorrect personal or contact information.
  • Inaccurate details about your health history.
  • Incorrect dates or service information.
  • Incomplete information relevant to your care.
  • Other factual inaccuracies in your records.

Correction requests will be reviewed in accordance with applicable legal requirements.

Please note that a disagreement with a professional opinion, clinical assessment or documented observation does not automatically mean that the record must be changed.

Where a correction is not made, applicable legal requirements may provide you with the right to have a statement of disagreement attached to your record.

4. Requests Made by Family Members or Representatives

A family member, caregiver or other representative does not automatically have the right to access your personal health information.

Requests submitted by another person must be supported by appropriate legal authority or authorization.

Depending on the circumstances, this may include:

  • Written authorization from the individual.
  • Proof of authority as a substitute decision-maker.
  • Legal guardianship documentation, where applicable.
  • Other documentation recognized under applicable Ontario law.

Carenfly Nursing may verify the identity and authority of the person making the request before processing it.

5. How We Process Access and Correction Requests

When we receive a request, the following general process may apply:

Step 1: Request Submission

The individual or authorized representative submits an access or correction request.

Step 2: Identity and Authority Verification

We review the request and verify the identity and, where applicable, the legal authority of the person submitting it.

Step 3: Record Identification

We identify the relevant records and determine whether Carenfly has custody or control of the requested information or is authorized to process the request on behalf of the responsible Health Information Custodian.

Step 4: Review

The request is assessed in accordance with applicable privacy legislation and any relevant exceptions.

Step 5: Response

We communicate the outcome and, where applicable, provide access to the requested records or explain the decision concerning a correction request.

6. Response Times and Applicable Fees

Access and correction requests will be handled within the timeframes required by applicable legislation.

Under PHIPA, a Health Information Custodian generally has 30 calendar days to respond to a formal access request, subject to specific statutory extensions and exceptions.

Where legally permitted, reasonable fees may apply for certain access requests. Any applicable fees will be communicated in accordance with the relevant legal requirements.

We aim to handle requests in a clear, respectful and timely manner.

7. When Access May Be Limited or Refused

In certain circumstances, access to some or all requested information may be restricted or refused where permitted or required by law.

For example, legal exceptions may apply where disclosure could:

  • Create a serious risk of harm to an individual.
  • Reveal information about another person without appropriate authorization.
  • Disclose information protected by legal privilege.
  • Fall within another applicable statutory exception.

If access is refused, the responsible organization will provide an explanation and information about available review or complaint options where required.

8. Submitting an Access or Correction Request

To request access to your records or ask for a correction, please contact:

Carenfly Nursing – Privacy Office
Carenfly Inc.
Toronto, Ontario, Canada

Email: info@carenfly.com

Subject: Health Records Access or Correction Request

Please include the type of request you are making. For your protection, do not send detailed medical records, identity documents or other sensitive information through ordinary email unless a secure submission method has been provided.

You may also use the dedicated request form available through our Patient Center, where applicable.

9. Your Right to Raise a Privacy Concern

If you believe your access or correction rights have not been properly respected, you may raise your concern with Carenfly Nursing’s Privacy Office.

Where PHIPA applies, you may also have the right to contact the Information and Privacy Commissioner of Ontario (IPC).

Information and Privacy Commissioner of Ontario

Website: https://www.ipc.on.ca/

The IPC provides information about Ontario’s health privacy legislation and the process for raising concerns about access, correction and the handling of personal health information.


Carenfly Nursing | Transparency. Accountability. Respect for Your Rights.

A service of Carenfly Inc.
Toronto, Ontario, Canada

 

Data Security & Records Management

Carenfly Nursing | Ontario, Canada

1. Our Commitment to Data Security

Carenfly Nursing recognizes that personal information and personal health information require a high level of protection.

We are committed to maintaining responsible records management practices and implementing appropriate safeguards to protect patient information against unauthorized access, loss, theft, misuse, alteration or disclosure.

Our approach focuses on confidentiality, controlled access, secure information handling and responsible record retention.

We manage patient information in accordance with applicable privacy legislation, including Ontario’s Personal Health Information Protection Act, 2004 (PHIPA), where applicable.

2. Centralized Patient Records Management

Carenfly Nursing follows a centralized patient records management model.

Patient and service records are maintained through systems and processes designated by Carenfly, subject to applicable legal responsibilities and contractual arrangements.

This approach is intended to support:

  • Consistent patient record management.

  • Organized care documentation.

  • Controlled access to patient information.

  • Appropriate coordination between assigned care professionals.

  • Continuity of care.

  • Responsible record retention and disposal.

Authorized care professionals may access relevant patient information when necessary for their assigned responsibilities.

Centralized record management does not mean that every member of the organization has unrestricted access to every patient file.

3. Role-Based Access Control

Access to patient information is intended to be limited according to professional roles, assigned duties and applicable legal authority.

Depending on their responsibilities, authorized individuals may include:

3.1 Registered Nurses (RN)

Where appropriately authorized, Registered Nurses may access relevant nursing assessments, care plans, clinical documentation and other information necessary for their assigned professional responsibilities.

3.2 Registered Practical Nurses (RPN)

Where appropriately authorized, Registered Practical Nurses may access relevant patient information necessary for the nursing services and responsibilities assigned to them.

3.3 Personal Support Workers (PSW)

Personal Support Workers may access the information necessary to carry out their assigned personal care and daily living support responsibilities.

Access to clinical assessments, sensitive information or other records is restricted according to their role and applicable requirements.

3.4 Administrative Personnel

Authorized administrative personnel may access limited information necessary for scheduling, communication, service coordination and other approved administrative responsibilities.

Administrative access does not automatically include unrestricted access to clinical records.

4. Individual User Accounts and Access Permissions

Where electronic systems are used, access should be provided through individually assigned user accounts.

Our intended access management practices include:

  • Individual login credentials.

  • Appropriate authentication requirements.

  • Role-based access permissions.

  • Restrictions based on assigned patient responsibilities.

  • Periodic access reviews.

  • Timely removal or modification of permissions when responsibilities change.

  • Prohibition of unauthorized account sharing.

Each authorized user is responsible for protecting their account credentials and maintaining the confidentiality of information accessed through their account.

5. Secure Handling of Patient Information

Patient information must be handled through approved communication and recordkeeping channels.

Authorized personnel are expected to:

  • Access patient records only for legitimate work purposes.

  • Avoid discussing confidential information in public places.

  • Avoid sending patient information through unauthorized messaging applications.

  • Protect electronic devices used for work.

  • Prevent unauthorized individuals from viewing patient records.

  • Avoid storing patient information on personal devices unless specifically authorized under approved procedures.

  • Report suspected loss, unauthorized access or disclosure promptly.

Patient information must not be copied, downloaded, photographed or shared for personal purposes.

6. Electronic Records and Information Security

Electronic patient records require appropriate technical and administrative safeguards.

Depending on the systems implemented by Carenfly Nursing, these safeguards may include:

  • Encryption of stored and transmitted information.

  • Multi-factor authentication (MFA).

  • Secure user authentication.

  • Role-based access controls.

  • Access and activity logging.

  • Secure data backup arrangements.

  • System monitoring and security updates.

  • Protection against unauthorized access and cyber threats.

The specific security controls applied to patient information will depend on the technology platforms and service providers used.

7. Third-Party Technology and Service Providers

Carenfly Nursing may use third-party technology providers to support patient record management, scheduling, communication, secure storage and other operational activities.

Before a service provider is authorized to handle personal health information, appropriate privacy, security and contractual requirements must be assessed.

These arrangements may address:

  • Confidentiality obligations.

  • Authorized purposes for information processing.

  • Access restrictions.

  • Data storage and processing arrangements.

  • Security safeguards.

  • Privacy incident reporting.

  • Record return, retention and secure disposal.

  • Responsibilities when a service agreement ends.

Where PHIPA applies, third-party arrangements must also reflect the applicable requirements governing Health Information Custodians and their agents.

8. Patient Record Retention

Carenfly Nursing maintains records according to applicable legal, regulatory, contractual and operational requirements.

Retention periods may vary depending on:

  • The type of record.

  • The nature of the services provided.

  • Applicable professional recordkeeping requirements.

  • Legal and regulatory obligations.

  • Other legitimate record retention requirements.

Records will not be retained indefinitely without an appropriate reason.

Where Carenfly is responsible for maintaining records, retention procedures will be established to ensure that records remain appropriately protected throughout their required retention period.

9. Secure Disposal of Records

When personal information is no longer required and applicable retention obligations have been satisfied, records will be securely destroyed or disposed of.

Depending on the format, appropriate disposal methods may include:

  • Secure deletion of electronic records.

  • Secure destruction of paper documents.

  • Removal of unnecessary copies.

  • Appropriate disposal of storage devices.

  • Verification that information is no longer accessible through ordinary means.

Disposal procedures will take into account applicable legal and contractual requirements.

10. Access Monitoring and Accountability

Carenfly Nursing aims to maintain appropriate accountability for access to patient information.

Depending on the systems implemented, access monitoring may include:

  • Reviewing user access permissions.

  • Monitoring relevant access and activity records.

  • Investigating unusual or unauthorized access.

  • Reviewing access when personnel leave or change assignments.

  • Documenting relevant security and privacy incidents.

Individuals authorized to handle patient information are expected to comply with applicable privacy policies, confidentiality agreements and security procedures.

11. Contractor and Care Professional Responsibilities

Care professionals and contractors working with Carenfly Nursing are expected to protect patient information throughout their professional relationship with the organization.

Their responsibilities may include:

  • Following approved privacy and security policies.

  • Accessing only authorized patient information.

  • Using approved systems and communication channels.

  • Maintaining confidentiality.

  • Protecting login credentials and devices.

  • Reporting suspected privacy incidents.

  • Returning or securely disposing of information when instructed and legally permitted.

  • Complying with confidentiality obligations after their assignment ends.

Access permissions will be reviewed and removed when an individual’s authorized responsibilities end.

12. Questions About Data Security and Records Management

If you have questions about how your personal information or personal health information is stored, managed or protected, please contact:

Carenfly Nursing – Privacy Office
Carenfly Inc.
Toronto, Ontario, Canada

Email: info@carenfly.com

Subject: Data Security & Records Management Inquiry

For your protection, please do not send detailed medical records, passwords, identity documents or other sensitive information through ordinary email unless a secure submission method has been provided.

You may also contact the Information and Privacy Commissioner of Ontario (IPC) for information about your privacy rights.

Website: https://www.ipc.on.ca/


Carenfly Nursing | Secure Records. Responsible Care.

A service of Carenfly Inc.
Toronto, Ontario, Canada

Privacy Complaints & Breach Reporting

Carenfly Nursing | Ontario, Canada

1. Our Commitment to Addressing Privacy Concerns

Carenfly Nursing takes the privacy and confidentiality of personal information and personal health information seriously.

We are committed to handling privacy concerns respectfully, reviewing complaints appropriately and taking reasonable steps to address identified issues.

If you believe your personal information has been collected, used, disclosed or handled inappropriately, you may contact our Privacy Office.

2. When Can You Submit a Privacy Complaint?

You may contact us if you have concerns about:

  • Unauthorized access to your personal health information.

  • Information being shared without appropriate authorization.

  • Incorrect or inappropriate use of your personal information.

  • Loss, theft or unauthorized disclosure of patient records.

  • Failure to protect confidential information.

  • Concerns about how your access or correction request was handled.

  • Other matters involving the privacy or confidentiality of your information.

You do not need to determine whether a privacy violation has occurred before raising a concern.

3. How to Submit a Privacy Complaint

You can submit a privacy complaint directly to Carenfly Nursing’s Privacy Office.

Please provide, where possible:

  • Your full name and preferred contact information.

  • A brief description of your concern.

  • The approximate date of the incident, if known.

  • Relevant details that may help us review the matter.

  • Your preferred method of communication.

Please avoid sending detailed medical records or other sensitive information through ordinary email unless a secure communication method has been provided.

4. How We Review Privacy Complaints

When a privacy complaint is received, we aim to follow an appropriate review process.

Step 1: Complaint Receipt

We acknowledge receipt of your complaint and identify the nature of your concern.

Step 2: Initial Review

We review the information provided and determine whether further investigation is necessary.

Step 3: Investigation

Where appropriate, we examine relevant records, access information, communications and other available evidence.

Step 4: Corrective Action

If an issue is identified, appropriate steps may be taken to address it and reduce the risk of recurrence.

Step 5: Response

We communicate the outcome or relevant next steps, subject to applicable privacy and legal requirements.

5. Privacy Breaches and Security Incidents

A privacy breach may occur when personal information or personal health information is lost, stolen, accessed, used or disclosed without proper authority.

Examples may include:

  • Sending patient information to the wrong recipient.

  • Unauthorized access to a patient record.

  • Loss or theft of a device containing patient information.

  • Sharing confidential information through an unauthorized channel.

  • Improper access to electronic patient records.

  • Accidental disclosure of personal health information.

Carenfly Nursing is committed to taking appropriate steps when a suspected privacy incident is identified.

Depending on the circumstances, our response may include:

  • Containing the incident and preventing further unauthorized access.

  • Securing affected records or systems.

  • Assessing the nature and scope of the incident.

  • Identifying individuals whose information may have been affected.

  • Documenting the incident and actions taken.

  • Notifying affected individuals and regulatory authorities where required by applicable law.

  • Implementing corrective and preventive measures.

6. Notification of Affected Individuals

Where notification is required by applicable law, affected individuals will be informed in accordance with the relevant legal requirements.

Depending on the circumstances, notification may explain:

  • What happened.

  • What personal information may have been affected.

  • What steps have been taken to address the incident.

  • What actions individuals may consider taking.

  • How to contact Carenfly Nursing for further information.

We recognize the importance of clear and timely communication when a privacy incident affects an individual’s information.

7. Reporting to the Information and Privacy Commissioner of Ontario

Where PHIPA applies, certain privacy breaches must be reported to the Information and Privacy Commissioner of Ontario (IPC).

The IPC oversees Ontario’s privacy legislation and provides information about individuals’ privacy rights.

Depending on the circumstances, you may have the right to raise a complaint directly with the IPC if you believe your personal health information has not been handled appropriately.

Information and Privacy Commissioner of Ontario

Website: https://www.ipc.on.ca/

You may also contact the IPC for information about your rights and available complaint procedures.

8. Protection Against Retaliation

Carenfly Nursing aims to ensure that individuals can raise privacy concerns respectfully and without fear of inappropriate treatment.

Submitting a privacy complaint will not, by itself, be a reason to treat an individual unfairly or deny access to services.

We encourage patients, family members and authorized representatives to raise concerns whenever they believe information has not been handled appropriately.

9. Contact Our Privacy Office

For privacy complaints, suspected information breaches or questions about confidentiality, please contact:

Carenfly Nursing – Privacy Office
Carenfly Inc.
Toronto, Ontario, Canada

Email: info@carenfly.com

Subject: Privacy Complaint – Carenfly Nursing

Please do not include passwords, detailed medical records or unnecessary sensitive information in your initial email.

We will provide an appropriate method for sharing additional information if required.


Carenfly Nursing | Your Privacy Matters. Your Concerns Matter.

A service of Carenfly Inc.
Toronto, Ontario, Canada

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Federally Incorporated in Canada
Corporation Number: 1724247-6
Ontario Corporation Number: 1001328577
Toronto, Ontario, Canada

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