PHIPA Statement

1. Introduction

Averra Care ("Averra Care," "we," "our," or "us") is committed to protecting the privacy and confidentiality of Personal Health Information ("PHI") in accordance with the Personal Health Information Protection Act, 2004 (PHIPA) and its regulations.

This statement applies to all PHI collected, used, and disclosed by Averra Care in the course of providing home care and support services, staffing and workforce solutions, wellness programming, and related services. Averra Care is headquartered in London, Ontario, and operates across Southwestern Ontario.

As a health information custodian under PHIPA, Averra Care takes its obligations seriously and has implemented policies, procedures, and safeguards to protect the PHI entrusted to us.

2. What Is Personal Health Information?

Under PHIPA, Personal Health Information includes identifying information about an individual that relates to:

• Physical or mental health, including family health history
• The provision of health care to the individual
• Plans of service under the Home Care and Community Services Act
• Payments or eligibility for health care
• Donation of body parts or bodily substances
• The individual's health number
• The identity of a substitute decision-maker

PHI may be in any form — oral, written, or electronic.

3. Collection of Personal Health Information

Averra Care collects PHI only for legitimate purposes directly related to the provision of care and services.

PHI may be collected:

• Directly from the individual or their substitute decision-maker
• From referring healthcare providers or care coordinators
• From hospitals, physicians, or other health information custodians with appropriate consent or authority
• Through care assessments and intake processes

We collect only the minimum amount of PHI necessary for the identified purpose.

4. Consent

Averra Care obtains consent before collecting, using, or disclosing PHI, except where PHIPA permits collection, use, or disclosure without consent.

Consent must be:

• Knowledgeable — the individual understands what they are consenting to
• Related to the information — consent is specific to the PHI and purpose
• Given by an authorized person — the individual or their substitute decision-maker
• Not obtained through deception or coercion

Individuals have the right to withdraw consent at any time, subject to legal or safety limitations. Withdrawal of consent may affect our ability to provide certain services.

Where consent is implied (e.g., for circle of care disclosures), we rely on the reasonable expectations of the individual in the context of their care.

5. Use of Personal Health Information

Averra Care uses PHI only for the purposes for which it was collected or for consistent purposes permitted under PHIPA.

Permitted uses include:

• Providing, coordinating, and managing care and support services
• Developing and implementing individualized care plans
• Communicating with the individual's circle of care
• Scheduling and staffing care visits
• Billing and administration related to services provided
• Quality improvement and risk management activities
• Compliance with legal and regulatory obligations
• Research and education, where permitted and with appropriate safeguards

6. Disclosure of Personal Health Information

Averra Care discloses PHI only with consent or as permitted or required by PHIPA.

Disclosures may be made:

• To members of the individual's circle of care for the purpose of providing care
• To substitute decision-makers as authorized
• To government bodies or regulatory authorities as required by law
• In emergency situations where there is a risk to life or safety
• To agents of Averra Care who require the information to perform their duties, subject to confidentiality obligations
• For research or quality improvement purposes, with appropriate safeguards and where permitted under PHIPA

We do not sell PHI. All disclosures are limited to the minimum necessary information.

7. Safeguards & Security

Averra Care implements reasonable administrative, technical, and physical safeguards to protect PHI against theft, loss, and unauthorized use, disclosure, copying, modification, or disposal.

8. Retention & Disposal

Averra Care retains PHI only as long as necessary to fulfill the purposes for which it was collected, or as required by law.

Retention periods are guided by:

• Applicable legislation and regulatory requirements
• Healthcare documentation standards
• Operational and legal needs

When PHI is no longer required, it is securely destroyed or anonymized in accordance with our records management procedures.

9. Individual Rights Under PHIPA

Under PHIPA, individuals have the following rights with respect to their PHI held by Averra Care:

Requests to exercise these rights should be submitted in writing to our Privacy Officer. We will respond within the timelines required by PHIPA.

10. Privacy Breaches

Averra Care has procedures in place to identify, contain, and respond to privacy breaches involving PHI.

In the event of a breach, we will:

• Contain the breach and assess the risk of harm
• Notify affected individuals where required under PHIPA
• Notify the Information and Privacy Commissioner of Ontario where required
• Document the breach and our response
• Implement measures to prevent recurrence

If you believe your PHI has been compromised, please contact our Privacy Officer immediately.

11. Privacy Officer & Contact Information

Averra Care has designated a Privacy Officer responsible for overseeing compliance with PHIPA and our privacy policies.

For privacy inquiries, access requests, complaints, or to report a potential breach, please contact:

You also have the right to contact the Information and Privacy Commissioner of Ontario at www.ipc.on.ca if you have concerns about how your PHI has been handled.

12. Updates to This Statement

This PHIPA Statement will be reviewed and updated periodically to reflect changes in legislation, our practices, or our services.

Updated versions will be posted on our website with a revised effective date. We encourage individuals to review this statement periodically.