PIPEDA and document collection for Ontario RCICs
PIPEDA and document collection for Ontario RCICs
Immigration files are sensitive personal information at scale: biometrics-adjacent photos, police certificates, bank letters, children's birth certificates.
Direct answer
PIPEDA applies to commercial RCIC activity. Use Canadian-hosted, access-controlled collection (Hivi-X) so passports are not sitting in Gmail. That supports your safeguard story; it is not a PIPEDA certificate. OPC guidance: privacy for businesses.
Why intake channel is a privacy control
| Channel | Typical issue |
|---|---|
| Unencrypted email | Copies on multiple mail servers; easy to mis-address |
| Device-level risk; not your records system | |
| Default Google Drive | Transborder hosting; link forwarding |
| Hivi-X guest OTP / portal | Scoped to the grant; Canadian hosting; encryption in transit and at rest |
Technical claims you can repeat if they match current security docs: Canadian servers, AES-256-GCM at rest, TLS, self-hosted AI (no third-party AI on client content). Verify /security for the live wording.
Minimum necessary collection
A checklist that only asks for this program's items is easier to defend than “send me everything.” Do not add clinical records to a medical-exam line unless IRCC requires them. See medical collection.
CICC confidentiality is stricter than a retention clock
Files: at least six years after closure. Confidentiality: indefinite. Deleting the Drive folder when you close the CRM card can be the wrong move. Pair with retention.
What Hivi-X does not do
- Answer access/correction requests for you
- Run your breach playbook
- Replace a written privacy policy or vendor review
- Auto-enforce CICC destruction schedules
Related: Canadian hosting, Google Drive comparison.
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General information only. Not immigration, privacy, or legal advice. Hivi-X is document-collection software — not a licensed immigration consultant. Not affiliated with or endorsed by CICC, IRCC, or the Office of the Privacy Commissioner of Canada.
Answers are general operational information only — not legal, tax, regulatory, clinical, privacy, immigration, or professional advice. Requirements vary by matter, client, and regulator.
Frequently asked questions
- Does PIPEDA apply to RCIC practices in Ontario?
- Commercial consulting is typically PIPEDA-covered federal private-sector privacy law. You still have CICC confidentiality (indefinite) on top. Confirm with privacy counsel for your structure.
- Is Canadian hosting required by PIPEDA?
- PIPEDA is about comparable protection and transparency for transborder flows, not a simple 'must be in Canada' slogan. Hosting in Canada still reduces a common client and CICC-complaint talking point versus default US Drive.
- Does using Hivi-X make my practice PIPEDA compliant?
- No. You remain responsible for consent, retention, access requests, vendor due diligence, and breach response. Hivi-X provides technical safeguards (Canadian servers, encryption, scoped guest access).
- Is emailing a passport PIPEDA-friendly?
- Unencrypted email is a weak safeguard for highly sensitive ID. Prefer guest-link upload. See email-is-not-collection in this folder.
- How long should I keep immigration documents?
- CICC file retention is at least six years after closure; confidentiality is indefinite. Your privacy policy should say what you keep and why. Hivi-X does not auto-purge per CICC clocks.
Collect complete immigration client files without the chase
Hivi-X helps Ontario RCICs collect passports, police certificates, employer letters, and IRCC forms with reusable checklists, the my-id.ca client portal, self-hosted AI summaries, and exportable PDF packages for your client file archive — alongside your immigration CRM.
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