888-823-6422
Last updated: March 14, 2025
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use our service and informs you about your privacy rights and how the law protects you.
We use your personal data to provide and improve our service. By using the service, you agree to the collection and use of information in accordance with this privacy policy.
NHC Information, Cybersecurity and Privacy Management Program
Navigation Home Care and Consulting Inc. (“NHC”) responsibilities:
NHC leadership supports a risk-aware, ethical, and continually striving to improve culture. We communicate, enforce, and maintain policies for managing cybersecurity risks.
NHC has appointed a Chief Privacy Officer / Chief Compliance Officer to be responsible for NHC’s PIPEDA, PHIPA and the Privacy Act compliance.
NHC protects all personal information held by our organization, including any personal information transferred to a third party including ShiftCare electronic charting system and/or QuickBooks Online for processing only with an individual's consent.
NHC has developed a Privacy Management Program and has implemented personal health information protection policies and practices. This program has been designed to comply with the Canadian privacy laws, including the Privacy Act, the PHIPA (Personal Health Information Protection Act), the PIPED (Personal Information Protection and Electronic Documents Act).
We also adhere to the ten fair information principles as outlined by the Office of the Privacy Commissioner of Canada;
1. Accountability:
NHC is responsible for the personal information we hold, we have a designated Privacy Officer to oversee privacy practices and implement safeguards.2. Identifying Purposes:
NHC clearly states the reasons for collecting personal information, and those purposes must be legitimate.3. Consent:
NHC obtains meaningful consent from individuals before collecting, using, or disclosing their personal information.4. Limiting Collection:
The collection of personal information should be limited to what is necessary for the identified purposes, and should be done fairly and lawfully.5. Limiting Use, Disclosure, and Retention:
Personal information can only be used, disclosed, or retained for the purposes for which it was collected, unless individuals consent to other uses or disclosures, or the law allows it.6. Accuracy:
NHC and its employees must ensure personal information is accurate, complete, and up-to-date to minimize the risk of using inaccurate information to make decisions about individuals.7. Safeguards:
NHC implements reasonable security measures to protect personal information from loss, theft, unauthorized access, or disclosure.8. Openness:
NHC is open about our policies and procedures related to handling personal information, and makes these policies readily available and easy to understand.9. Individual Access:
Individuals have the right to access the personal information that NHC holds about them, to challenge the accuracy and completeness of that information, and to have it amended if necessary.10. Challenging Compliance:
Individuals have the right to challenge NHC's compliance with PIPEDA.
Our designated Privacy Officer has the support of senior management and the authority to intervene on privacy issues.
We conduct privacy impact assessments and threat analysis of NHC’s personal information handling practices, including ongoing activities, new initiatives, and new technologies.
What personal information do we collect and is it sensitive? We collect sensitive personal information on our patients, clients and staff.
Why do we collect it? We collect sensitive information including sensitive health information on patients and clients in order to provide delivery of care with patient, client or substitute decision makers’ consent. We use the secure software ShiftCare electronic charting system to store sensitive health information of patients and clients.
We also collect sensitive information from our staff for the purposes of Human Resources operations including background checks, payroll and for tax purposes. This information is securely stored only on QuickBooks Online.
How do we collect it? We collect personal and health information directly from patients, clients, their families or substitute decision makers with consent through the verbal interview intake process, reports and instructions from hospital discharge planners and treatment teams, family and treating physicians, or other healthcare agencies or providers with patient / substitute decision makers’ written consent.
What do we use it for? We use personal health information for the purpose of delivery of care, to develop care plans, and to ensure that relevant health concerns are being addressed properly. We use personal information from patients and clients to collect payments, and we collect personal information from staff to conduct the background checks, for submitting tax information, and for payroll purposes.
Where do we keep it? Our information is stored on secure electronic systems including Shiftcare electronic charting system and QuickBooks Online for payment information and payroll.
How is it secured? We use secure software including ShiftCare and QuickBooks which helps safeguard your data and protect your privacy by using industry-leading technology and practices. ShiftCare prioritizes the security and integrity of their software platform, and are committed to safeguarding user data and complying with Canadian regulations, striving to maintain the highest standards of security. Quickbooks and ShiftCare use multi-factor authentication for sign in and safeguards your information by encrypting it when it’s stored in their systems. This means that they translate your information into a code that only they can read to make sure only you and Intuit or ShiftCare have access to your information.
Who has access to or uses it? Access is limited to the appropriate staff assigned to a particular patient or client on a need to know basis. Staff's personal information is stored securely on ShiftCare and QuickBooks and access to sensitive information is strictly limited to the appropriate human resources manager on a need to know basis. All NHC staff undergo mandatory training on Cyber Security with routine reviews.
Who do we share your information with? We do not share any of your personal information without you or your substitute decision makers’ written consent, except where required by law, or in the event of a medical emergency to receiving hospitals or emergency medical personnel. We share payment information with the Canada Revenue Agency.
When is it disposed of? QuickBooks will retain your data for a period of 12 months after cancellation of services.
NHC maintains a list of all centralized inventory assets (physical and virtual systems and devices) that store PHI. We also have a data retention and destruction timetable of 12 months.
NHC conducts its own regular Cyber Security Risk Assessment / Internal Audit.
This Information, Cybersecurity and Privacy Management Program shall be reviewed quarterly or more frequently if deemed necessary by the Chief Privacy Officer to assess for and address any shortcomings.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: info@navigationhomecare.ca
By visiting this page on our website: https://www.navigationhomecare.ca/
By phone number: (888)823-6422
Last Reviewed May 5, 2025