Personal Health Information & Privacy Policy

Co-Care Health Group Inc. ("Co-Care", "we", "us", or "our") is designated as a Health Information Trustee under the Personal Health Information Act (PHIA, C.C.S.M. c. P33.5) of the Province of Manitoba.

As a provider of licensed in-home nursing, personal care, and specialized health services across Manitoba (including Steinbach, Winnipeg, Selkirk, Portage la Prairie, Winkler, Morden, and surrounding rural communities), we maintain legal custody and control of Personal Health Information (PHI). Every employee, Registered Nurse (RN), Licensed Practical Nurse (LPN), Health Care Aide (HCA), and direct support worker is bound by statutory confidentiality pledges, professional nursing codes of ethics (CRNM & CLPNM), and Co-Care's corporate privacy governance mandates.

We hold ourselves accountable to the Manitoba Ombudsman and Manitoba Health, ensuring every record is collected with informed consent, handled with clinical discretion, and guarded against unauthorized access or disclosure.

Under PHIA, we collect only the amount of personal health information necessary to deliver safe, effective, and tailored healthcare services. This includes:

Sources of Collection: We collect personal health information directly from the client whenever possible. Where the client lacks legal capacity or has designated an authorized representative, information is gathered from substitute decision-makers (such as an appointed Health Care Proxy or Committee of Both Personal Care and Property). We may also receive records from referring entities, including Regional Health Authorities (Southern Health-Santé Sud, Winnipeg Regional Health Authority), discharge coordinators, or primary care physicians.

Co-Care Health Group adheres to the strict principle of "need-to-know." Information is accessed only by authorized clinical and administrative personnel directly involved in your care plan or regulatory administration:

• Clinical Care Coordination: Registered Nurses, Licensed Practical Nurses, and Health Care Aides use health data to carry out customized nursing care plans, monitor clinical trends, and update family caregivers.
• Interdisciplinary Communication: Sharing relevant health updates with your attending physician, community pharmacists, physiotherapists, or hospital discharge planners to guarantee seamless continuity of care.
• Funding & Billing Administration: Providing necessary verification of services delivered to third-party funding bodies (e.g., Regional Health Authority Self-Managed Care programs, MPI adjusters, VAC, or private insurers).
• Emergency Medical Dispatch: Releasing critical health metrics, medication lists, and advance care directives to paramedics, 911 dispatchers, or emergency room trauma teams in urgent life-threatening crises.

Co-Care implements defense-in-depth security measures to protect electronic and physical health records against accidental loss, unauthorized access, copying, modification, or exposure:

Physical records (e.g., initial ink-signed agreements or temporary paper charts) are secured in locked, fire-resistant clinical filing cabinets with restricted keycard access at our Steinbach operational center.

Under Part 2 of Manitoba's Personal Health Information Act, you possess statutory rights over your clinical records:

• Right to Inspect and Obtain Copies: You have the right to inspect your health records or request certified paper or electronic copies. Requests must be submitted in writing to our Privacy Officer.
• Right to Request Correction: If you believe there is an error or omission in your health record, you may submit a written request for amendment. We will append an official correction or, if the clinical finding is disputed, attach a statement of disagreement to your file.
• Right to Know About Disclosures: You may request an accounting of disclosures detailing which third-party entities have accessed your records outside the routine care team.

Consent to collect, use, and disclose personal health information may be express (written or verbal) or implied within the circle of care. A client may withdraw or modify consent at any time, provided the withdrawal does not prevent the provision of legally mandated or life-sustaining care.

Substitute Decision-Makers: If an individual is incapable of making health care decisions, Manitoba law permits an authorized substitute decision-maker to exercise privacy rights on their behalf, prioritized as follows:

1. A Health Care Proxy appointed under The Health Care Directives Act.
2. A Committee of the Person appointed under The Mental Health Act.
3. A Substitute Decision-Maker appointed under The Adults with Intellectual Disabilities Act.
4. Spouse, common-law partner, adult child, parent, or next of kin in descending order of statutory priority.

Co-Care retains client health records in full compliance with Manitoba Health regulations, the College of Registered Nurses of Manitoba (CRNM) Practice Expectations, and the Manitoba Personal Health Information Act:

• Adult Records: Retained for a minimum of ten (10) years following the date of the last clinical service provision.
• Pediatric / Minor Records: Retained for ten (10) years past the client's 18th birthday (until age 28).

Upon expiration of the retention window, records are securely destroyed using certified cryptographic digital erasure protocols or NAID-certified physical cross-cut shredding with formal certificates of destruction.

Co-Care maintains an immediate incident response plan for actual or suspected privacy breaches. In the unlikely event that personal health information is stolen, lost, or accessed without authority:

1. Immediate containment and digital isolation of the affected system or record.
2. Risk assessment evaluating the sensitivity of data, probability of misuse, and identity of affected individuals.
3. Mandatory notification to affected clients or their legal proxies without unreasonable delay.
4. Formal report dispatch to the Office of the Manitoba Ombudsman where mandated by provincial regulations.

If you have questions regarding this policy, wish to request access to or correction of your medical records, or wish to report a privacy concern, please contact our Privacy Officer: