Privacy Policy

PRIVACY CODE FOR OUR DENTAL OFFICE

This Privacy Code generally applies to any personal information collected or generated by the dental office operated by Clinique dentaire Daher Inc., which provides professional dental services comprising of diagnosis, the interpretation of x-ray radiographs produced by the Affiliate, treatment planning and intra-oral professional services at 5512 Chemin de la Côte-des-Neiges, Suite 201Montréal, Québec  H3T 1Y9 (the “Office”). The Affiliate means DCC Health Services (Quebec) Inc. and/or an affiliate or agent thereof, which provides institutional health care services, including dental laboratory, radiological and other diagnostic services, and the operation of dental operatories and dental equipment.

Personal information means any information which relates to a patient and allows that patient to be identified. Personal information about our patients is usually collected directly from the patient or from the person acting on their behalf. Occasionally, we collect personal information about a patient from other sources if we have obtained the patient’s consent to do so or if the law permits.

The protection of personal information and your privacy is an important principle in the provision of quality care to our patients. We understand the importance of protecting your personal information.  We are committed to collecting, using and disclosing your personal information responsibly and in accordance with the law.  We also intend to be transparent about the way we handle your personal information.

This Office has developed this Privacy Code to provide a general description of our information and communication practices, how to obtain access to your personal information, how to amend incorrect information, and how to make a complaint to our Office or the Québec Commission d'accès à l'information. As the rules governing the collection, use, and disclosure of personal information may change, our practices will evolve and adapt in response to such changes, and this Privacy Code may be amended from time to time as a result thereof

We ask that you contact our Privacy Officer in the event you have any questions or concerns regarding this Privacy Code or its implementation.

LEGAL FRAMEWORK

The Office is subject to An Act respecting the protection of personal information in the private sector (Québec) which came into effect in 1994, An Act to establish a legal framework for information technology which came into effect in 2001, the Code of Ethics of Dentists, as well as other relevant related regulations pertaining to the management of patients’ files (“Privacy Laws”). In addition, Canada’s anti-spam legislation (“CASL”) came into effect on July 1, 2014 and regulates how businesses and individuals communicate electronically with outside parties.

ANTI-SPAM POLICY OVERVIEW

When we communicate with you, we may communicate via electronic means, such as e-mail. You can always limit the communications that our Office sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account. If you have any questions about your choices or if you need any assistance with opting-out, please contact our Privacy Officer (see section entitled “How to Contact Us” for details). In the event that our Office inadvertently sends out a CEM without consent, we commit to investigating every such instance and assisting the employee(s) or managers involved with renewing their understanding and awareness of our compliance responsibilities.

PERSONAL INFORMATION HANDLING PRINCIPLES

Accountability

Accountability for this Office’s compliance with Privacy Laws rests with our Privacy Officer even though others in the Office may be responsible for the day-to-day collection and processing of personal information.

Our staff is briefed on the importance of your privacy and receives training on the handling of your personal information.

Our Office is comprised of many persons working together to ensure that our patients and clients receive proper care.  At our Office, professional dental or orthodontic services may be performed by service providers. All institutional health care services performed at the Office are provided by our Affiliate. To facilitate the ability of our Affiliate to carry out its responsibilities to us, your personal information may be disclosed to, used by, and collected by our Affiliate.

All actions by our Affiliate in respect of your personal information shall be in compliance with this Privacy Code and applicable Privacy Laws.  By providing your personal information to this Office, you are consenting to its use by us, our service providers and our Affiliate.  We have permitted our Affiliate to collect, use, disclose, retain, or dispose of our patients’ personal information which we ourselves may collect, use, disclose, retain, or dispose of, provided that its actions are not contrary to the limits imposed by Privacy Laws or such other applicable law.  We have informed our Affiliate of its duties under Privacy Laws and other applicable law.

This Office is responsible for personal information in our possession or custody, including personal information that has been transferred to a third party for processing.

Our Office is implementing policies and practices to give effect to the principles regarding the collection, use and disclosure of personal information, including:

  • implementing policies to protect personal information;
  • training staff about this Privacy Code and our practices;
  • establishing procedures to receive and respond to complaints and inquiries regarding personal information; and 
  • developing information to explain this Privacy Code and privacy procedures.

Identifying Purposes for Collecting Information

The purposes for which personal information is collected in this Office will be identified before or at the time it is collected.

This Office collects personal information that is reasonably appropriate in the circumstance in order to fulfill the purposes disclosed by our Office, as well as otherwise permitted under applicable laws including for the following purposes:

  • to deliver safe and efficient patient care;
  • to identify and to ensure continuous high quality service;
  • to assess your health needs;
  • to advise you of treatment options;
  • to enable us to contact you;
  • to provide health care;
  • to establish and maintain communication with you, including to distribute health care information and to book and confirm appointments;
  • to offer and provide treatment, care and services in relationship to the oral and maxillofacial complex and dental care generally;
  • to communicate with other treating health-care providers, including specialists and general dentists, who are the referring dentists and/or peripheral dentists;
  • for teaching and demonstrating purposes on an anonymous basis;
  • to allow us to efficiently follow-up for treatment, care and billing;
  • to complete and submit dental and health services claims for third party adjudication and payment;
  • including the delivery of patients’ charts and records when required by law;
  • to comply with agreements/undertakings entered into voluntarily by this Office or a service provider for regulatory and monitoring purposes;
  • to permit potential purchasers, practice brokers or advisors to evaluate this Office, including an audit, on a confidential basis;
  • to deliver your charts and records to insurance carriers to enable them to assess liability and quantify damages;
  • to prepare materials as required by applicable law;
  • to manage patient and clients’ accounts, including invoicing, processing credit card payments and collecting unpaid accounts;
  • to communicate with insurance companies and to otherwise process requests by you;
  • for internal management purposes, including planning, resource allocation, policy development, quality improvement, monitoring, audit, evaluation, reporting, obtaining or processing payment for health services and human resource management; and
  • to comply generally with Privacy Laws and all other applicable regulatory requirements.

When this Office collects personal information we will only collect personal information necessary for the purpose we identify to you before or at the time of collection.

When personal information has been collected and is to be used or disclosed for a purpose not previously identified, the new purpose will be identified prior to its use or disclosure. Your consent will be obtained before the personal information will be used or disclosed for any such new purpose.

When you sign the Patient Consent Form, you will be deemed to understand and accept this Office’s collection, use and disclosure of your personal information for the specified purposes, in each case subject to this Privacy Code and Privacy Laws.

Consent

We require consent from our patients before we may collect, use, or disclose their personal information. The Privacy Laws also provides instances where we may collect, use, or disclose your personal information without consent.

In order for the principles of consent to be satisfied, our Office has undertaken reasonable efforts to ensure that you are advised of the purposes for which personal information is being used, and that you understand those purposes. Once consent is obtained, we do not need to seek your consent again unless the use, purpose or disclosure changes.

Our existing protocols for electronic submissions of dental claims require a signature on file. Specific consent may be required for additional requests from insurers.  This consent shall be collected at the time, or in conjunction with, predetermination for extensive services, provided that the scope of personal information released is disclosed. If there is any doubt, personal information shall be released directly to you for your review and submission.

Your consent for the collection, use and disclosure of personal information may be given in a number of ways, such as:

  • signed medical history form;
  • e-mail;
  • signed introductory questionnaire;
  • taken verbally over the telephone and then charted; or
  • written correspondence.

Unless restricted by law, you may withdraw your consent upon reasonable notice to our Office.

For children, a parent or other lawful guardian may consent to the collection, use or disclosure of their personal information even if the child has capacity.

When our Office needs consent for the collection, use or disclosure of personal information about a child, we may either obtain it from that child if capable, as well as the parent or other lawful guardian (but not the access parent, unless such a parent has been lawfully authorized in place of the custodial parent to make information decisions).

In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:

  • where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
  • when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information;
  • to collect a debt; and
  • to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.

For more information on how Office may share your personal information, please refer to the section Sharing of Personal Information below.

Sharing of Personal Information

Your personal information may be made available by our Office to third-parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Code. We may share your personal information when authorized by law or as follows:

  • Third party or affiliated service providers. We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by Office to perform work on its behalf, including for the collection of customer accounts, customer credit verification, installation of services and quality control assessment. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others. Our Office will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections that are, at a minimum, equivalent to those employed by Office itself.
  • As permitted or required by law. From time to time, our Office may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We may release certain personal information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
  • Business transaction. We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of our business. However, in the event the transaction is completed, your personal information will remain protected by applicable Privacy Laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.

Only those employees of our Office or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about patients.

Cross-Border Transfer 

This Office and our Affiliates may perform activities outside of Canada through third party agents. You acknowledge and agree that as a result, your personal information may be processed, used, stored or accessed in other countries in which case your personal information may be subject to these foreign laws. For example, your personal information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these other countries.

Retention

Our Office has protocols in place for the retention of personal information, which are in compliance with applicable Privacy Laws, regulations and guidelines applicable to our Office.

Accuracy of Personal Information

This Office endeavours to ensure that your personal information is as accurate, complete, and as up-to-date as necessary for the purposes that it is to be used. The extent to which your personal information is accurate, complete and up-to-date will depend upon the use of the personal information while at all times, taking into account the interest of our patients.

If your personal information changes, or if you believe the personal information maintained by our Office is inaccurate, we ask that you contact our Office to have the information updated or corrected.

Safeguards for Personal Information

Our Office staff is aware of the importance of maintaining the confidentiality of your personal information and we have taken appropriate measures to safeguard your personal information. 

These safeguards are in place to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Your personal information is protected, whether recorded on paper or electronically, and care is used in its care and destruction of to prevent unauthorized access at all times while in our care and control.

Patient Access to Personal Information

Upon written request and with reasonable notice, you shall be informed of the existence, use and disclosure of your personal information, and shall be given access to it.

Upon written request and with reasonable notice, our Office shall provide you with an accounting of how your personal information has been used, including third party disclosures. In providing this information, we will attempt to be as specific as possible. We will respond to your request within a reasonable period of time and in any event, within thirty (30) days, and at minimal or no cost to you. The request for information will be provided or made available in a form that is generally understandable.

You are free to challenge the accuracy and completeness of your personal information and seek to have it altered, amended, or changed. When a challenge is not resolved to your satisfaction, we will record the substance of the unresolved challenge accordingly. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the personal information in question. This disclosure may be appropriate where a dentist has been challenged about a change to a service date or services rendered under consideration for insurance benefits.

Challenging Compliance

You shall be able to challenge compliance with these principles with the Privacy Officer who is accountable for compliance with Privacy Laws as well as other laws and regulations which may apply to our Office. Our Office has in place procedures to receive and respond to your complaints or inquiries. The procedures are easily accessible and simple to use.

Our Office has an obligation to inform our patients who make inquiries about how to access the privacy complaint process in our Office, and about how to access that process. The Privacy Officer will investigate each and every complaint made to the Office in writing.

If a complaint is found to be justified, the Privacy Officer will take appropriate measures, including, if necessary, amending any policies and practices.

Updating this Privacy Code

Any changes to our privacy standards and information handling practices will be reflected in this Privacy Code in a timely manner and if the changes are significant, we will provide a more prominent notice. Our Office reserves the right to change, modify, add, or remove portions of this Privacy Code at any time.

To determine when this Privacy Code was last updated, please refer to the modification date at the bottom of this Privacy Code.

How to Contact Us

Our Privacy Officer is our Affiliate. For more information about our privacy protection or communication practices, or to raise a concern you have with our practices, you may contact our Affiliate at:

21 St. Clair Avenue East, Suite #1420
Toronto, Ontario
M4T 1L9

Attention: Guy Amini, Chief Legal Officer

You have the right to complain to the Québec Commission d'accès à l'information if you think our Office has violated your privacy rights. 

Last update on April ●, 2016.

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