Is Your ABA Software PHIPA Compliant in Ontario?

If you’re running an ABA therapy clinic in Ontario, you handle personal health information (PHI) every day.

That makes you a “Health Information Custodian” (HIC) under Ontario’s Personal Health Information Protection Act (PHIPA).

And that means you’re legally responsible for how that data is collected, stored, used, and shared.

Many clinics use ABA software built for the U.S. market, assuming that HIPAA compliance is enough. It’s not. Ontario’s standards go further.

PHIPA has different rules, especially when it comes to consent, data residency, and access rights. If your software doesn’t meet those rules, your clinic could be exposed to legal risk, patient complaints, or compliance audits.

What PHIPA Actually Requires

PHIPA governs the handling of personal health information in Ontario. It gives clients rights over their data and requires you to take “reasonable steps” to protect that data. That includes:

Keeping PHI confidential and secure
Getting proper consent (implied or express, depending on the use)
Allowing clients to access or correct their records
Maintaining records for the required time periods (usually 10 years after last contact)
Reporting breaches where PHI has been lost, stolen, or accessed without authorization
For ABA clinics, this applies to everything from behaviour assessments to treatment notes and family communication logs.

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Common Gaps in ABA Software

Here are a few areas where ABA software often falls short of PHIPA requirements:

Data stored outside Canada: PHIPA doesn’t outright ban cross-border storage, but if data is hosted in the U.S., you must inform clients and may need to obtain express consent. Many clinics aren’t doing this.
Weak audit trails: You must be able to track who accessed which client files and when. Some software only offers limited logs.
Lack of access controls: PHIPA requires that only authorized staff members have access to client data. If your system doesn’t support user roles, you’re exposed.
No way to handle client access requests: Clients have a right to request a copy of their records. Your software should support exporting and redacting files if needed.
Vague consent tracking: You need to know whether consent was implied or express, and for what purpose. Good software helps with that.

What to Ask Your Software Provider

To assess whether your current software meets PHIPA requirements, ask:

Where is client data stored? (Canada, U.S., or elsewhere?)
Can we track who accessed client files and when?
Does the software support role-based access?
Can we easily provide clients with a copy of their records?
Does the system support documenting consent?

If the answers are unclear, your current platform may not be PHIPA-compliant.

What Happens if You’re Not Compliant?

Using software that doesn’t meet PHIPA requirements can put your clinic at serious risk. Consequences can include:

Formal complaints from clients to the Information and Privacy Commissioner of Ontario
Mandatory investigations or audits by the Commissioner
Fines or penalties if your clinic is found to have mishandled personal health information
Loss of professional reputation and client trust if there’s a privacy breach
Difficulty responding to client record requests or breach notifications as required by law

The longer you continue using non-compliant software, the greater the exposure.

How Portia Helps

Portia Pro was built in Ontario for Ontario clinics. That means PHIPA compliance isn’t a retrofit; it’s part of the foundation.

All data is stored on Canadian servers
Full audit logs are built in
Role-based access and user permissions are standard
Export tools make client record requests simple
Consent tracking is supported directly in the client profile

We know these features matter because we rely on them ourselves. We’re held to the same standards as you are, understand what’s at stake, and use Portia Pro in our own Ontario-based ABA clinics.

Final Thoughts

PHIPA compliance is a legal requirement, not a checkbox. If you’re not sure whether your current software meets those requirements, now’s the time to find out.

Want help? Book a quick call with our team. We’ll walk you through what PHIPA requires and how Portia Pro helps you meet those obligations without adding more to your plate.