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What do PHIPA, PIPEDA, and HIPAA expect from a business owner?

January 11, 2026 by
What do PHIPA, PIPEDA, and HIPAA expect from a business owner?
USOC Inc., USOC Security

Most business owners, when they hear regulatory abbreviations like PHIPA, PIPEDA, or HIPAA, tend to skip over them. Not because they are irresponsible, but because these regulations feel distant, complex, and irrelevant to day-to-day business operations. Many assume that compliance is only required for large corporations or hospitals, and that running a business simply means incorporating, paying taxes, and delivering services.

The reality is different.

For many medium-sized businesses, regulatory compliance only becomes a concern after a cyber incident when data is lost, systems are disrupted, or regulators start asking questions. By then, the damage is already done. The repercussions often include loss of sensitive data, business downtime, reputational harm, heavy fines, and, in some cases, legal prosecution.

One of the biggest challenges business owners face is not unwillingness, but complexity. These regulations are difficult to understand, harder to relate to real business activities, and even harder to translate into practical, implementable controls.

We aim to simplify what PHIPA, PIPEDA, and HIPAA actually require of a small or medium-sized business owner, using plain language and real-world logic.


What are these regulations really about?

Despite their different names and jurisdictions, PHIPA, PIPEDA, and HIPAA are built on the same core principles. These regulations revolve around the collection, storage and transmission of data. For business, this means data about their customers, vendors, employees and billing and operational records. 

In order for these regulations to work, small and medium businesses (SMBs) should be able to relate compliance requirements to their business activities, translate them into actionable controls, and implement them effectively to achieve compliance.


What regulators expect from a medium-sized business?


Regulators do not expect small and medium businesses to operate like large enterprises. What they expect is reasonable, consistent, and provable control over data.


The data story regulators actually follow:


Data enters the organization through customer forms, patient appointments, employee records, or vendor interactions. At this stage, regulators expect businesses to collect only what is necessary and to be transparent about the purpose.

Once collected, data is stored across systems such as cloud platforms, internal applications, databases, email systems, laptops, and backups. Regulators expect secure storage, appropriate encryption, and awareness of where data resides, including geographic location.

As data is used, employees access it to perform their roles. From a compliance perspective, access should be limited to what is required and traceable if reviewed.

Data is also shared with third parties such as payroll providers, cloud vendors, IT service providers, and software platforms. Accountability typically remains with the business that controls the data, even when vendors are involved.

Finally, regulators assess how incidents are handled. The focus is on detection, response, and communication rather than fault.

This data journey forms the foundation of most privacy and data protection requirements.


How PHIPA, PIPEDA, and HIPAA fit into this story?

PHIPA, PIPEDA, and HIPAA map directly onto the same data lifecycle. The differences lie mainly in scope and strictness. Understanding applicability is the first step toward compliance.

  • PHIPA (Ontario - Health-related businesses): Applies to businesses that handle personal and health information in Ontario. This includes healthcare providers, clinics, labs, pharmaceuticals and even IT or SaaS vendors that store or process health data on their behalf.

  • PIPEDA (Canada - General): Applies to most Canadian businesses that collect, use, or disclose personal information in the course of commercial activity. This includes customer data, employee data, vendor information, and online data.

  • HIPAA (USA - Health-related businesses): ​Applies to health-related businesses and insurers dealing with protected personal​and health information in the United States.

Importantly, HIPAA can apply outside the US if your business handles US health-related data directly or indirectly.


PHIPA vs PIPEDA vs HIPAA - A Comparison

Data Area

PHIPA (Ontario –Health)

PIPEDA (Canada – General)

HIPAA (USA – Health)

1. Applicability & Data Type

Healthcare businesses in Ontario

Personal Health Information

Businesses handling personal data in Canada

Personal Information

Healthcare businesses & insurers

Protected Health Information

2. Data Examples

Health records, charts, and lab results

Names, email, phone, billing, IDs

Medical records, insurance data

3. Data Collection & Use

Collect only what is needed for care

Use only for healthcare operations

Collect only for stated business purpose

Use only for the declared purpose

Minimum necessary for treatment

Use for treatment, payment, operations

4. Consent & Transparency

Implied or explicit consent

Meaningful consent required

Consent embedded in care workflows

5. Data Storage & Location

Secure systems (Canada preferred)

Secure storage with location disclosure

Secure systems with strict safeguards

6. Access & Authentication

Role-based staff access

Strong passwords recommended

Need-to-know access

Reasonable security controls

Role-based, logged access

Strong authentication required

7. Encryption & Logging

Encryption expected

Audit logs expected

Encryption expected

Audit logs good practice

Encryption mandatory 

Audit logs mandatory

8. Data Sharing & Vendors

Share only with authorized parties

Vendors must protect PHI

Share only with consent or legal basis

Vendors must ensure the same protection

Business Associate Agreements (BAA) required

9. Breach Response

Report to IPC + individuals

As soon as feasible

Report to OPC + individuals

As soon as feasible

Report to HHS + individuals

Within 60 days

10. Policies, Training & Penalties

Privacy policies + staff trainingFines, orders, prosecution

Privacy policy required

Fines, reputational damage

Mandatory training

Heavy fines, criminal penalties


This overlap explains why compliance feels confusing. Businesses are not managing three separate problems. They are managing the same data handling expectations expressed in different regulatory language.


Translating compliance into practical actions

PHIPA, PIPEDA, and HIPAA describe outcomes such as consent, safeguards, and accountability. Businesses need to translate those outcomes into operational actions.

The table below maps regulatory expectations to practical IT and security controls that SMBs can implement.


1. Data Collection & Classification

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Data classification

Identify sensitive data and treat it more carefully

Label data as PHI / PII so it gets extra protection

Required

Expected

Required

Minimum data collection

Collect only what is truly needed

Limit fields in forms and systems

Mandatory

Mandatory

Mandatory

Consent management

Get permission and keep proof

Store consent flags and logs

Required

Required

Required


2. Access Control & Authentication

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Role-based access (RBAC)

Staff see only what they need

Restrict access by job role

Required

Expected

Required

Strong authentication

Prevent weak or stolen logins

Strong passwords + MFA

Recommended

Reasonable safeguard

Required

Access reviews

Remove access that is no longer needed

Quarterly user access reviews

Expected

Expected

Required


3. Data Storage, Encryption & Retention

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Encryption (When Stored)

Protect stored data if stolen

Encrypt databases and backups

Recommended

Reasonable safeguard

Required

Encryption (In transit)

Protect data while moving

TLS, VPNs, secure email

Recommended

Expected

Required

Secure backups

Ensure data can be recovered safely

Encrypted, tested backups

Required

Required

Required

Data retention policy

Keep data only as long as needed

Define retention & deletion rules

Required

Required

Required

Secure deletion

Permanently remove unused data

Secure wipe when no longer needed

Required

Required

Required


4. Monitoring, Logging & Reviews

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Audit logging

Track who accessed data

Log access, edits, downloads

Expected

Good practice

Mandatory

Log retention

Preserve logs safely

Secure, tamper-resistant log storage

Expected

Expected

Required

Risk assessment

Identify and fix the biggest risks

Annual security risk review

Expected

Expected

Mandatory


5. Infrastructure & Endpoint Protection

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Patch management

Fix known vulnerabilities

Regular OS, app, device updates

Expected

Expected

Required

Endpoint security

Protect laptops & servers

AV / EDR on devices

Expected

Reasonable safeguard

Required

Network security

Block unauthorized access

Firewalls, network segmentation

Expected

Reasonable safeguard

Required

Physical security

Prevent physical access

Locked rooms, badge access

Required

Required

Required


6. Vendors & Third Parties

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Vendor risk management

Ensure vendors protect data

Security review of vendors

Required

Required

Required

Vendor agreements

Make protection legally binding

Privacy clauses / BAA

Required

Required

Mandatory BAA

Data residency awareness

Know where data is stored

Track data location & country

Strongly expected

Mandatory disclosure

Not location-bound


7. Breach Detection & Response

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Breach detection

Notice incidents quickly

Monitoring and alerts

Expected

Expected

Required

Breach response plan

Know what to do

Incident response playbooks

Required

Required

Required

Breach notification

Notify on time

Predefined timelines & templates

Mandatory

Mandatory

Mandatory


8. People, Policies & Training

Control

What it means

What you actually do (IT action)

PHIPA

PIPEDA

HIPAA

Employee training

Staff handle data safely

Annual privacy & security training

Required

Required

Mandatory

Policy documentation

Rules are written and enforced

Security & privacy policies

Required

Required

Required


Most of these controls are not advanced or enterprise-only. Many SMBs already implement parts of them informally. The gaps are in consistency, visibility, and documentation. This is why surveys consistently show complexity as the biggest barrier. Regulations are often presented without showing how they map to daily business operations.


What this means for SMB owners

PHIPA, PIPEDA, and HIPAA are not asking SMBs to become legal experts. They expect businesses to understand their data, apply reasonable safeguards, and be able to explain their approach when asked.

If a business can clearly answer what data it collects, why it collects it, where it is stored, who can access it, and how incidents are handled, it is already aligned with core regulatory expectations.

Privacy compliance is not a separate project. It is part of good data management and cybersecurity hygiene.


Turning regulations into actionable controls

Medium businesses do not need enterprise-level complexity. What regulators expect is:

  • Defined access controls
  • Strong authentication
  • Secure storage and encryption
  • Audit logs
  • Staff awareness and training
  • Breach preparedness

When a business can demonstrate these controls, compliance follows naturally.


Final takeaway

PHIPA, PIPEDA, and HIPAA are not barriers to running a business. They are frameworks designed to protect trust between businesses, customers, vendors, and regulators.

For a medium business owner, compliance is not about mastering legal language. It is about understanding the data you handle, limiting unnecessary risk, and implementing controls that grow with your business.

When approached correctly, compliance becomes a business strength, not a burden

Even though HIPAA is a health-related regulation, it encompasses most of the compliance criteria. If you implement HIPAA-level controls, you will automatically meet or exceed PHIPA and PIPEDA in most cases.

Most compliance problems in SMBs do not come from ignoring data protection. They come from postponing it because it feels complex and disconnected from daily operations.

When privacy regulations are viewed through the story of data, they stop feeling abstract. They become a structured way to reduce risk, build trust, and protect the business before an incident forces the conversation.

That shift, from reacting to planning, is what separates businesses that struggle with compliance from those that handle it confidently.


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References:

https://www.ontario.ca/laws/statute/04p03

https://www.ipc.on.ca/en/resources/guidance-organizations

https://www.hhs.gov/hipaa/index.html