Kitchener and New Hamburg Denture Clinic
Privacy of personal information is an important principle to us at Kitchener Denture Clinic. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.
WHAT IS PERSONAL INFORMATION
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number), their health (e.g., health history, health conditions, health services received by them) or their activities and views (an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.
WHO WE ARE
Our organization, Kitchener Denture Clinic, includes at the time of writing one Denturist and support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include associates, contract staff, volunteers, students, support dental professionals, computer, software and website consultants, bookkeepers and accountants, lawyers, governing institutions, financial institutions, insurance companies, maintenance and cleaning companies,. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES
Like all denturists, we collect, use and disclose personal information in order to serve our clients. For example, we collect information about a client’s person (including name, home contact information, , insurance benefit coverage, date of birth, gender, marital status, a client’s health history (including health history, medications), a client’s dental history (including oral or denture concerns, condition of dentures, age of existing dentures) and a client’s oral and denture condition (including documenting, the number and condition of remaining teeth, oral hygiene, alveolar ridge atrophy and mobility, condition of alveolar ridge, jaw relationship, jaw condition, general intra-oral and extra-oral soft tissue condition, denture assessment, prognosis or other opinions formed during assessment and treatment, patient expectations and attitudes towards proposed treatments), a client’s appointments (including dental procedures preformed, advice or recommendations given to client by the denturist, clients opinions, attitudes and compliance towards treatments, payment history, existence of a dispute. We collect the above information in order to help us assess our client’s health and dental needs, to advise them of their options and provide the dental care they choose to have.
For our clients, the primary purpose for collecting personal information is to provide treatment in the scope of Denturism. A second primary purpose is to obtain a baseline of health and dental information so that in providing ongoing health services we can identify changes that are occurring over time. It would be rare for us to collect such information without the clients express consent, but this might occur in an emergency (e.g., the client is unconscious) or where we believe the client would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our client and we have no reason to believe that the message is not genuine).
In the case where a client is incapable of making financial or health related decisions for him/herself in respect to a proposed assessment or treatment, that client’s power of attorney information and consent will be required. In this case the power of attorney name and contact information as well as any financial information may be required. This information may be used for primary and secondary purposes.
About Members of the General Public
Re: members of the general public, our primary purposes for collecting personal information are to make them aware of Denturist services in general or our clinic in particular as well as notices of special events ( e.g., a seminar or open house). While we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reasons possible, we will upon request immediately remove any personal information from our distribution list.
On our website we only collect, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to subscribe to our newsletter).
About Contract Staff, Volunteers and Students
Re: people who are contracted to do work for us, our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments or contracts) and for necessary work-related communications (e.g., sending out paycheques, year end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in case of a health emergency (e.g., SARS or any other infectious disease outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the clinic). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.
WE COLLECT PERSONAL INFORMATION: SECONDARY AND RELATED PURPOSES
Like most organizations, we also collect, use and disclose information for purposes secondary or related to our primary purposes. The most common examples of our related and secondary purposes are as follows:
Invoice clients for goods or services to paid for at the time, to process credit/debit card and personal cheque payments or to collect unpaid accounts:
Forward any delinquent accounts to a reputable collection agency. The information disclosed to the collection agency will include client’s name, contact information and account history.
Recall clients for oral and denture check-ups, to ensure the appliance is still functioning properly and appropriate for their then current needs and/or consider modifications or replacements.
Advising clients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new treatment).
Follow up letters to consultations or treatment.
Providing clients with newsletters providing information about our clinic and any new treatments available
Our clinic reviews client and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality assurance reviews of our Clinic, including reviewing client files and interviewing staff.
Your name will be used on in-house and/or commercial laboratory prescription scripts. This will ensure accuracy in tracking your case throughout all procedures, in an in house/commercial dental laboratory.
Denturists are regulated by the College of Denturists of Ontario who may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our organization believes that it should report information suggesting serious illegal behavior to the authorities. External regulators have their own strict privacy obligation. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services). Also, like all organization, various government agencies (e.g., Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
The cost of some goods/services provided by our Clinic to clients is paid for by third parties (e.g., WSIB, DVA, NIHB, private insurance). These third-party payers often have your consent or legislative authority to direct us to collect or disclose to them certain information in order to demonstrate client entitlement to this funding.
Clients or other individuals we deal with may have questions about our goods or services after they have been received. We also provide ongoing services for many of our clients over a period of months or years for which our previous records are helpful.
Records in the form of intra-oral or extra-oral photos may be obtained and used for internal records, internal/external promotion or educational purposes. You will be asked for consent in these specific situations. You will receive a consent form before proceeding.
In certain situations a referral to another dental practitioner (such as a dental specialist or dentist), or a physician may be necessary prior to treatment at our Clinic. In this situation information about a client’s person, a client’s health and dental history, a clients or denturist opinions or attitudes and/or appointment history may be shared with the professional.
Your information is required in circumstances to control infections disease outbreaks (e.g., S.A.R.S)
In the case where Kitchener Denture Clinic or its assets were to be sold, the purchaser may wish to conduct a “due diligence” review of the Clinic’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have confirmed the intent to buy the organization’s business or its assets would be provided access to personal information and only for the purpose of completing their due diligence search prior to closing the purchase.
You can choose not to be part of some of these related or secondary purposes whenever possible (e.g., by declining to receive notice of special events or opportunities). We do not however, have much choice about some of these related or secondary purposes (e.g., external regulations).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Paper information is either under supervision or secured in a locked or restricted area.
Electronic hardware is either under supervision or secured in locked or restricted area at all times. In addition, passwords and firewalls are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.
Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
External consultants and agencies with access to personal information must enter into a privacy agreement with us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any question you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
Our regulatory College (The College of Denturist of Ontario) obligates our Clinic to maintain and have access to client’s records for a period of at least 5 years after your final visit at our Clinic. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence (i.e., with people who are not clients) newsletters, seminars and marketing activities for about 1 year after the newsletter ceases publication or seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire client file to our client.
YOU CAN LOOK AT YOUR INFORMATION
With only a few exceptions, you have the right to see what personal information we hold about you, upon written request. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A QUESTION?
Kitchener Denture Clinic
622 Charles Street East
Kitchener, N2G 2R5
Phone: (519) 894-8885
or you can email us
He will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. He will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing within 60 days.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us.
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some exceptions to the commitments set above.
For more general inquiries, the information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The commissioner also acts as a kind of ombudsman for privacy disputes. The information and privacy commissioner can be reached at:
112 KENT STREET, OTTAWA, ON K1A 1H3
PHONE 1-800-282-1376, www.privcom.gc.ca