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Privacy Impact Assessment (PIA)

Date: January 3, 2026 Project: CareConnect (v12.0) Status: Initial Assessment

1. Project Overview

CareConnect (CareConnect) is a community-led social services directory. It provides public access to information about food, housing, crisis, and health services.

2. Data Inventory & Data Flow

2.1 Information Collected

Data Element Type Source Purpose Storage
Feedback Content Free Text User Submission Data quality improvement Supabase DB
Partner Email Contact Info Partner Registration Authentication & Verification Supabase Auth
Partner Name Contact Info Partner Registration Verification Supabase DB
Session Data Metadata Browser Language/Theme preferences LocalStorage (Client)
IP Address Metadata Network Security/Rate Limiting Server Logs (Vercel)

2.2 Information NOT Collected

  • Search Queries: No server-side logging of search terms.
  • Chat Conversations: All AI processing is client-side (WebLLM). No conversation data leaves the user's device.
  • Tracking Cookies: No analytics or ad-tech cookies used.

3. Privacy Risks & Mitigation

Risk 1: Sensitive Feedback Data

Risk: Users might inadvertently include personal health information (PHI) in feedback forms. Mitigation:

  • Warning label on feedback forms ("Do not include personal information").
  • Feedback is private, accessible only to admins and the specific verified partner.
  • 90-day retention policy for resolved feedback.

Risk 2: Partner Identity Exposure

Risk: Partner emails could be exposed or misused. Mitigation:

  • Row-Level Security (RLS) policies enforce strict access control.
  • Partner emails are not displayed publicly unless they are the official service contact email.

Risk 3: AI Hallucinations

Risk: AI assistant provides incorrect medical/crisis advice. Mitigation:

  • Local-only processing: Privacy-preserving by design.
  • Strict System Prompts: Instructed to disclaim medical advice.
  • UI Disclaimers: Prominent warnings about AI limitations.
  • Emergency Interception: UI detects crisis keywords and shows 911 banner.

4. Compliance Assessment

PIPEDA

  • Accountability: Privacy Officer designated (Project Lead).
  • Consent: Implied consent for service use; explicit opt-in for AI.
  • Limiting Collection: Minimal data collection policy enforced.
  • Safeguards: Encryption in transit (TLS) and at rest (Supabase).

PHIPA (Health Information)

  • CareConnect is not a Health Information Custodian (HIC).
  • CareConnect does not purposefully collect PHI.
  • "Zero-Log" policy for search queries prevents incidental collection of sensitive health interests.

5. Recommendations

  1. Implement automated scrubbing of potential PHI from feedback fields.
  2. Conduct annual access review for partner accounts.
  3. Formalize data sharing agreement with 211 Ontario if data synchronization is implemented.

Approved By: CareConnect Governance Committee