Each Therapist who provides care to clients registered through Safer Spaces is a health information custodian (“Health Information Custodian”) under Ontario’s health privacy legislation, the PHIPA. In this Policy, “we” and “our” refers to the Therapists, and Safer Spaces acting as their agent. To that end, in order to fulfill their privacy obligations as Health Information Custodians, the Therapists and Safer Spaces have entered into a legal agreement to make Safer Spaces an agent of the Therapists under PHIPA. As an agent of the Therapists, Safer Spaces has a variety of roles, including acting as privacy officer for each of the Therapists, and for running the overall privacy program on their behalf. Safer Spaces is also a custodian of personal information and subject to the Protection of Personal Information and Electronic Documents Act in respect of personal information that it collects from Clients that does not relate to Client Services.