> ## Documentation Index
> Fetch the complete documentation index at: https://docs.getrivet.ca/llms.txt
> Use this file to discover all available pages before exploring further.

# PHIPA and Rivet

> How Rivet's role under Ontario's PHIPA is characterized — agent of the practitioner-custodian, provider of electronic services, not an EHR.

If you're a registered psychotherapist, social worker, psychologist, or
counsellor in Ontario, you operate as a **health information custodian**
under the *Personal Health Information Protection Act, 2004* (PHIPA). The
people who call your practice number, leave voicemails, or text are sharing
information that PHIPA treats as personal health information (PHI). That
includes the fact that they reached out to a mental health practitioner at
all.

When you use Rivet to handle those communications, Rivet's role is defined
in two specific places in PHIPA — and Rivet is designed around both.

## Rivet is your agent (PHIPA s.2)

PHIPA s.2 defines an "agent" as a person who, with a custodian's
authorization, acts for or on behalf of the custodian in respect of PHI.
That's the receptionist analogy made formal. A receptionist who handles
patient messages is an agent of the custodian under PHIPA — and a service
that transcribes voicemails, surfaces them in an inbox, and sends auto-replies
on your behalf falls in the same category.

Rivet acts as your agent. That means:

* Rivet handles PHI on your behalf and at your direction — never for its own
  purposes.
* The PHIPA accountability for that PHI stays with you. Rivet is bound to
  protect it; you are accountable for it.
* A written agreement between you and Rivet captures the boundaries of that
  agency. That's the Data Processing Agreement you accept when you sign up.

## Rivet is a provider of electronic services (O. Reg. 329/04 s.6(3))

Ontario Regulation 329/04 s.6(3) addresses a person who supplies services
that enable a custodian to use electronic means to collect, use, retain,
disclose, or dispose of PHI. That's Rivet's product description in legal
language.

Under s.6(3), Rivet:

* Uses PHI only as necessary to provide the service.
* Doesn't disclose PHI except to deliver the service or as required by law.
* Notifies you of any unauthorized handling at the first reasonable
  opportunity.
* On request, provides a plain-language description of the service and its
  safeguards.

## Rivet is not a custodian

Rivet doesn't provide health care, and Rivet isn't on the list of custodian
classes in PHIPA s.3. The client information Rivet handles belongs — in the
PHIPA sense — to you. If a client asks you for a copy of their records,
that's your obligation to fulfil under PHIPA s.52. Rivet's job is to give
you the facts you need to answer that request.

## Rivet is not a Health Information Network Provider

A HINP (O. Reg. 329/04 s.6(2)) is a service whose primary purpose is to
enable two or more custodians to disclose PHI to one another by electronic
means. Rivet enables communication between you and your clients — not
custodian-to-custodian disclosure. Different role, different obligations.

## What this means for you

You don't have to read the statute to use Rivet — but you should know the
shape of it, because regulators, insurers, and compliance officers will ask.
The short version:

1. You're the custodian. The PHI is yours.
2. Rivet is your agent. The DPA captures Rivet's duties to you.
3. Rivet uses client information only to deliver the service you subscribed
   to — never for its own purposes, never for marketing, never to train any
   AI system.
4. If a client asks for access, correction, or deletion of their information,
   you handle that request as the custodian — and Rivet helps you do it.

## Outside Ontario

PHIPA is Ontario-specific. If you practice in another province, the
*federal* PIPEDA baseline applies, plus your provincial health-privacy
statute (Alberta's HIA, B.C.'s PIPA, Quebec's Law 25, etc.). The Rivet
posture — agent of the custodian, electronic-service provider, no
secondary use, minimum necessary handling — translates cleanly to those
regimes. If your College or your insurer wants the equivalent local
characterization in writing, email `hello@getrivet.ca`.

## Related articles

<CardGroup cols={2}>
  <Card title="Your role as custodian" icon="user-shield" href="/privacy/your-role-as-custodian">
    What being a PHIPA custodian means day-to-day, and what Rivet handles on
    your behalf.
  </Card>

  <Card title="The Data Processing Agreement" icon="file-signature" href="/privacy/data-processing-agreement">
    The agreement that papers the agency relationship.
  </Card>

  <Card title="Measurement vs. clinical content" icon="ruler" href="/privacy/the-measurement-results-vs-clinical-content-distinction">
    Why Rivet stays a communication tool, not a clinical record system.
  </Card>
</CardGroup>
