While we have always respected our clients, privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Ontario’s Personal Health Information Protection Act (PHIPA) and Personal Information Protection and Electronic Documents Act (PIPEDA). This sets out how staff members who come in contact with your personal information are aware of the sensitive nature of the information that you have disclosed to us. In this form we have outlined what we do to ensure that:
- Only necessary information is collected about you
- Start Fresh Dental Hygiene only shares your information with your consent
- Storage, retention and destruction of your personal information complies with existing legislation and privacy protection protocols
- Our privacy protocols comply with privacy legislation, standards of regulatory body (CDHO) and the law
- Accuracy, confidentiality, and security of our clients’ personal information will be of utmost importance as well as allowing our clients to request access to, and correction of, their personal information
Personal Information – means information about an identifiable individual E.g., including name, age, home address and phone number, medical information, education, employment information]. Personal information does not include contact information (described below).
Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PHIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Start Fresh Dental Hygiene complies with this policy and PHIPA.
Policy 1 – Collecting Personal Information
- 1.1 – Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
- 1.2 – We will only collect client information that is necessary to fulfill the following purposes:
- To assess your dental health needs and provide health and dental care
- To deliver safe and efficient and continuous high quality client care
- To advise you of treatment options
- To enable us to contact you to distribute health-care information and to book and confirm appointments
- To allow us to provide follow-up for treatment, care, and billing
- To establish and maintain communication with you
- To offer and provide dental hygiene care
- To communicate with other treating health-care providers, including specialists, general dentists, and hygienists who are the referring providers and/or peripheral providers
- To complete and submit dental claims for a third party adjudication, pre-approval when necessary and payment.
- To invoice for goods and services
- To process credit card, debit, and cheque payments
- To collect any unpaid accounts; this may include a referral to a third party collection agency and may include that agency reporting unpaid accounts to a credit Bureau
- To comply with legal and regulatory requirements, including the delivery of client’s charts and records to the College of Dental Hygienists of Ontario in a timely fashion, when required, according to the provisions of the Regulated Health Professions Act
- To comply with agreements /undertakings entered into voluntarily by the member with the College of Dental Hygienists of Ontario, including delivery and/or review of client’s charts and records to the College in a timely fashion for regulatory and monitoring purposes
- To permit potential purchasers, practice brokers or advisors to conduct an audit in preparation for a practice sale and to purchase such information but only as part of the purchase practice
- To deliver your charts and records to the hygienist’s insurance carrier to enable the insurance company to assess liability and quantify damages, if any
- To prepare materials to the Health Professional Appeal and Review Board (HPARB)
- To assist our company and hygienists to comply with all regulatory requirements
- To comply generally with the law
We understand the importance of protecting personal information.
Policy 2 – Consent
- 2.1 – We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
- 2.2 – Consent can be provided [e.g., orally, in writing, electronically, through an authorized representative] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
- 2.3 – Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer, member does not opt-out.
- 2.4 – Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Start Fresh Dental Hygiene to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.
- 2.5 – We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
- 3.1 – We will only use or disclose a client’s personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct client, customer, member surveys in order to enhance the provision of our services;
- To contact our clients directly about products and services that may be of interest;
- To order products from our lab that are being custom made for our client;
- 3.2 – We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
- 3.3 – We will not sell client lists or personal information to other parties.
Policy 4 – Retaining Personal Information
- 4.1 – If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client as a reasonable opportunity to request access to it.
- 4.2 – Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
- 5.1 – We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
- 5.2 – Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
- 5.3 – If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.
Policy 6 – Securing Personal Information
- 6.1 – We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
- 6.2 – The following security measures will be followed to ensure that client personal information is appropriately protected:
[locking filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls, secured data server exclusive to Start Fresh Dental Hygiene restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures].
- 6.3 – We will use appropriate security measures when destroying client’s personal information such as [shredding documents, deleting electronically stored information].
- 6.4 – We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients Access to Personal Information
- 7.1 – Clients have a right to access their personal information, subject to limited exceptions.
- 7.2 – A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. [A request to access personal information should be forwarded to the Privacy Officer]
- 7.3 – Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
- 7.4 – We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
- 8.1 – The Privacy Officer is responsible for ensuring Start Fresh Dental Hygiene’s compliance with this policy and the Personal Information Protection Act.
- 8.2 – Our Privacy Information Officer is Rose Dalla Pasqua RDH and can be reached at 289-245-1045 or email: firstname.lastname@example.org