AON Builds Communities

Respecting Your Privacy

Protecting privacy and acting responsibly with personal information is fundamental to AON’s values and how it does business. We are committed to protecting the privacy of our residents and the confidentiality and security of all personal health information entrusted to us. Our practices regarding the collection, use, and retention of personal information are guided by responsible policies and procedures, and are compliant with all applicable legislation.

Personal Health Information

The Personal Health Information Protection Act, or the “PHIPA”, is the provincial law that governs the collection, use and disclosure of personal health information. Its purpose is to keep personal health information confidential and secure, while allowing for the effective delivery of health care. Personal Health Information, or “PHI”, includes any identifying information about an individual’s health or health care, such as:

  • clinical information, for example lab or X-ray results;
  • medication information,
  • health history,
  • payments or eligibility for health care coverage
  • one’s health provider, and
  • one’s health card number.

Under the PHIPA, each of AON’s Long-Term Care homes and its retirement homes, The Gardens of Peterborough, are “Health Information Custodians”. The PHIPA prescribes certain obligations on Health Information Custodians to protect personal health information and to collect and use it within defined circumstances. The obligations include the following broad categories. AON has established policies and staff education to promote compliance with them:

  1. responding to requests for access to, and correction of, records of PHI;
  2. ensuring transparency of information practices;
  3. the proper collection, use and disclosure of PHI,
  4. maintaining PHI security, and
  5. privacy breach management.

The “agents” of Health Information Custodians share these obligations. This includes employees of the long-term care or retirement home, as well as any volunteers who have any access to personal health information, plus persons contracted to provide services to the Home who have access to personal health information (e.g. pharmacy, physiotherapy, labs, etc.).

Collection, Use, and Disclosure

AON’s long-term care and retirement homes collect personal health information about our residents, either directly from the resident or from a person acting on their behalf. The information that we collect may include, for example, resident photographs (for identification purposes), name, date of birth, address, health history, and records of the care a resident receives in one of our Homes. We may also collect personal health information from other sources, such as a previous health care provider, if this information is needed by us to provide residents with necessary treatment and care.

We use and disclose resident personal health information for a variety of reasons, as outlined below, all of which are permitted by legislation. When we use personal health information for resident care, only the staff members involved in that care may access the information. AON Homes use and disclose personal health information to:

  • Treat and care for our residents
  • Conduct risk management activities
  • Educate and orient new staff
  • Comply with legal and regulatory requirements
  • Plan, administer and manage internal operations
  • Obtain payment for your treatment and care
  • Conduct quality improvement activities
  • Fulfill other purposes permitted or required by law
  • Facilitate the adoption of regional and provincial electronic health records. As these systems are put into place to improve safety and quality of care, your personal health information will be stored and shared securely on health information databases accessible only by authorized health care providers.

We will not use or disclose your personal health information for any marketing or fundraising purposes. Our own, internal resident-services staff may access and use contact information for follow-up and to enquire about satisfaction with our services. Unless you tell us differently, we may let visitors or callers know that a resident resides in one of our Homes.

Security of Personal Health Information

We are committed to keeping resident information safe and confidential. AON’s long-term care and retirement homes take steps to protect personal health information from theft, loss and unauthorized access, copying, modification, use, disclosure and disposal. The protection of Personal Health Information includes many elements, ranging from physical safeguards (such as locked filing cabinets and restricted access to offices where personal health information is held), to technical safeguards (such as the use of passwords, encryption, and audits), to administrative safeguards (such as policies and procedures, employee education, and the use of confidentiality agreements with our agents).

Access and Correction

As a resident you may access and correct your personal health information, or withdraw your consent for some of the above uses by making a simple request to your Administrator (subject to legal exceptions, such as where disclosures are required by law). You will be asked to put your request in writing, to enable us to verify the existence of the record in question and to locate it for you. We will respond to access requests within the timeframes set by the PHIPA, and at a reasonable cost.

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the Home will correct the information as required. Otherwise, the individual may require that a statement of disagreement be attached to the record of personal information.


Consent is required for the collection, use, and disclosure of personal health information. In general, a custodian who provides health care, such as a long-term care or retirement home, is permitted to collect, use and disclose personal health information, on the basis of implied consent, for the purpose of providing health care. This consent extends to the agents of the home, and other health information custodians with whom we collaborate to provide a resident’s care. For certain matters, including those prescribed by the PHIPA, we will seek express consent from a resident or their SDM. Consent for the collection, use, and disclosure of personal health information may be expressly withheld or withdrawn by a resident or their SDM, although such a withdrawal cannot be applied retroactively.

Enquiries and Complaints

For more information or to raise a concern about our practices, please contact:

Privacy Officer
AON Inc.
307 Aylmer Street North
Peterborough, Ontario
K9J 7M4
Phone: 705-742-5445, Ext. 2242

Residents have the right to complain to the Information and Privacy Commissioner of Ontario if they think we have not managed their personal health information appropriately by contacting:

Information and Privacy Commisioner of Ontario
2 Bloor St. East, Suite 1400
Toronto, Ontario
M4W 1A8
Toll Free: 1-800-387-0073

Return to the AON Homepage