Your practice
It matters enormously, and the answer is not what most people assume. Custodian status runs along a closed list, not along how medical your profession looks.
The Health Information (Ministerial) Regulation designates a fixed list of thirteen colleges. It includes physicians, pharmacists, dentists, dental hygienists, denturists, opticians, optometrists, dietitians, midwives, podiatrists, registered nurses, chiropractors, and physiotherapists.
Physiotherapists were added on 22 June 2026 and are newly obligated.
Acupuncturists are not on the list. Neither are psychologists. They fall under Alberta's Personal Information Protection Act instead, which is a materially lighter regime with no requirement to file a privacy impact assessment.
So a chiropractor and an acupuncturist in the same building are under entirely different rules. The chiropractor must file a privacy impact assessment with the Commissioner before introducing or changing any system handling health information, must maintain a written record of their safeguards, and must produce a privacy management program within thirty days of a request. The acupuncturist must do none of those things.
Check the list, not your intuition. If your college is one of the thirteen, you have filing obligations that carry real deadlines. If it is not, you are under PIPA and the requirements are far lighter than most compliance marketing implies.
If you are a custodian and have never filed a privacy impact assessment, that is worth professional help. The Alberta Medical Association publishes a list of consultants with their fee bands, currently $750 to $2,500. Expect a long wait: the Commissioner's office receives roughly 2,500 filings a year with eight staff, and says review may take up to twelve months.
A · Verified
Checked 6 Sep 2026 · Review by Mar 2027
Health Information (Ministerial) Regulation AR 106/2026 read directly at Alberta King's Printer. Physiotherapist designation confirmed via the College of Physiotherapists of Alberta. Filing volumes and the twelve-month figure from the Alberta OIPC 2024-25 Annual Report and its published PIA guidance. Consultant fee bands published by the Alberta Medical Association.
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