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Privacy Policy

PR I V A C Y AN D ANT I - SPA M COD E FO R OU R DE NT A L OF F I C E
 
Please refer to Appendix A for a glossary of defined terms.
 
INTRODUCTION
 
The Personal Health Information Protection Act, 2004 (PHIPA) came into effect on November 1, 2004, and governs the collection, use,   and   disclosure   of   Personal   Health   Information   within Ontario’s health care system, and the Personal Information Protection and Electronic Documents Act, which came into effect in 2001, governs Personal Information other than Personal Health Information.
 
In addition,  Canada’s  anti-spam  legislation  came  into effect  on July 1, 2014. Canada’s anti-spam legislation regulates how businesses and individuals communicate electronically.
 
We collect Personal Information about our patients 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.
 
Privacy of Personal Information 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 try to be as open and transparent as possible about the way we handle your Personal Information.
 
This Office has developed this Privacy and Anti-Spam Code (this “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 Information and Privacy Commissioner.   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 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  Code  or  its implementation.
 
ANTI-SPAM POLICY OVERVIEW
When we communicate with you, we may communicate via electronic means, such as e-mail. We strive to ensure that our communications do not contain any spam. “Spam” refers to any unsolicited  Commercial   Electronic  Messages  (or  CEMs)  that have been sent without consent.  In that light, we require all CEMs from our Office to be in compliance with Privacy Laws.   If and when we communicate with you using CEMs, you can opt out of receiving such messages by following the “Unsubscribe” link included at the bottom of such messages or by contacting Mandy Sawka (905) 952-3308.   Any questions or concerns with respect to CEMs from our Office may be addressed Mandy Sawka (905) 952-3308. 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.

PE
RSONAL 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  are  briefed  on  the  importance  of  your  privacy  and receive 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.  Some of our team members are Health Information Custodians and some are not.  We take this opportunity to describe the structure of our Office so that you understand who may be handling your Personal Information and in what manner.
 
At  our  Office,  professional  dental  or  orthodontic  services  are performed  by  Service  Providers.    All  professionals  performing these services at the Office are Members of the College and are considered  Health  Information  Custodians.       All  institutional health care services performed at the Office are provided by our Affiliate.  The individuals providing the institutional health care services for our Affiliate may be Health Information Custodians whereas our Affiliate may not.   We have appointed our Affiliate as  our  “contact  person”  pursuant  to  the  Privacy  Laws.      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 Code and Privacy Laws.  By providing your Personal Information to this Office, you are consenting to its use by us, the 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 will implement 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 Code and our practices;
− establishing  procedures  to receive  and respond  to complaints and inquiries regarding Personal Information; and
− developing   information   to  explain   this  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;
− to comply with legal and regulatory requirements, including the delivery of patients’ charts and records to the College when required by the Regulated Health Professions Act (RHPA);
− to    comply     with    agreements/undertakings     entered     into
voluntarily by this Office or a Service Provider with the College 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  for  the  Health  Professions  Appeal  and
Review Board as required;
− 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 Code and Privacy Laws.
 
Consent
Our Health Information Custodians require either express consent or implied consent from our patients before we may collect, use, or disclose Personal Information.    When we collect, use, and disclose  your  Personal  Information  for  health  care  purposes,

Privacy  Laws  generally  permit  us  to  rely  upon  your  implied consent.   However, if the purpose is something other than health care, we may be required to obtain your express consent.  The Privacy Laws also provides instances where we may collect, use, or disclose your Personal Information without consent.
 
Implied consent enables us to conclude from surrounding circumstances that a patient would reasonably agree to the collection,  use, or disclosure  of Personal Information.   We may rely upon your implied consent if we are collecting your Personal Information to provide health care.
 
Express consent is required when we are disclosing your Personal Information  to  someone  other  than  a Health  Information Custodian,  or  to  another  Health  Information  Custodian  for  a purpose other than providing or assisting in providing health care.
 
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,   predeterminations   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.
 
You may withdraw your consent upon reasonable notice to our
Office.
 
For  children  under  16,  a  parent  or  other  lawful  guardian  may consent to the collection, use or disclosure of their Personal Information even if the child has capacity.  This does not apply to Personal Information that relates to:
− treatment within the meaning of the Health Care Consent Act, 1996 about which the child has made his or her own decision, or

− counselling in which the child has participated on his or her own under the Child and Family Services Act.
 
When   our   Office   needs   consent   for  the   collection,   use  or disclosure of Personal Information about a child less than 16 years of age, we may either obtain it from that child if capable, or 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).    If there  is a conflict in consent between the child and the parent, the capable child’s decision prevails with respect to the consent.
 
Limiting Use, Disclosure and Retention
Personal Information shall not be used or disclosed for purposes other  than  those  for which  the information  is collected,  except with your express Consent, or as required or permitted by law.
 
Our  Office  may  disclose  certain  Personal  Information  in accordance with Privacy Laws.
 
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 and may be subject to the laws of those  countries.  For example,  Personal  Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
 
We   will   use   contractual   and/or   other   means   to   provide   a comparable  level  of protection  over  your  Personal  Information while  it is  being  accessed  and/or  processed  by  any  such  third party.
 
Our Office has protocols  in place for the retention  of Personal Information.
 
Retention  of  information  records  is defined  and  referenced  in College’s Guidelines on Dental Recordkeeping.
 
In destroying Personal Information, our Office has developed guidelines   to   ensure   secure   destruction   in   accordance  with the College’s Guidelines on Dental Recordkeeping.
 
As discussed  in this Code, Personal  Information  may be transferred and stored outside of Canada.  We encourage you to contact  the  Privacy  Officer  should  you  require  further information.
 
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.
 
Your Personal Information needs to be sufficiently accurate, complete  and  up-to-date  to  minimize  the  possibility  that inaccurate,  incomplete   or  out-of-date   Personal  Information   is used to make a decision about you as our patient.
 
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 are 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.
 
Openness about Privacy
Our Office will make readily available to you specific information about our Office policies and practices relating to the management of Personal Information.
 
This information includes:
− the individuals at this Office and the Privacy Officer to whom you can direct any questions or complaints regarding your Personal Information;
− a  copy  of  our  Patient  Consent  Form  that  explains  how  this Office collects, uses and discloses your Personal Information; and
− this Code.
 
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.
 
When it is not possible to provide a list of the organizations or individuals to which there has been disclosure about you, we will provide  you  with  a list of such  organizations  or individuals  to which we may have disclosed information about you. Disclosure of probabilities in these cases would satisfy this requirement.
 
We will respond  to your  request  within  a reasonable  period  of time,   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 the Privacy Laws by each of our Health Information Custodians. 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 office policies and practices.
 
Updating this Privacy and Anti-Spam Code

Any changes to our privacy standards and information handling practices will be reflected in this Code in a timely manner. Our Office  reserves  the  right  to  change,  modify,  add,  or  remove portions of this Code at any time.
 
Please check this page periodically for any modifications. To determine when this Code was last updated, please refer to the modification date at the bottom of this 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, contact our Affiliate at:
 
21 St. Clair Avenue East, Suite #1420
Toronto, Ontario
M4T 1L9
Attention: Guy Amini, General Counsel
You have the right to complain to the Commission  if you think we have violated your rights.  The Commissioner can be reached at:
 
Information and Privacy Commissioner/Ontario
 
2 Bloor Street East
Suite 1400 Toronto, Ontario
M4W 1A8
 
1-800-387-0073 info@ipc.on.ca

APPENDIX –A DEFINITIONS
Affiliate – means Dental Corporation of Canada 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
 
Collection – The act of gathering, acquiring or obtaining personal information from any source, including third party sources by any means
 
College – Royal College of Dental Surgeons of Ontario
 
Commercial Electronic Message or CEM – is a message sent directly  to  an  electronic  address  (such  as  an  email  address,  a phone number, an instant messaging account, or social media account) with the purpose, or one of its purposes, of encouraging participation in a commercial activity.
 
Commissioner – The Information and Privacy Commissioner for the Province of Ontario
 
Consent – A voluntary agreement with what is being done or is being  proposed  to  be  done.  Consent  can  either  be  express  or implied. Express consent may be given explicitly, either orally or in writing
 
Disclosure  –  Making  Personal  Information  available  to  other health information custodians or other persons
 
Health  Information  Custodians  –  Means  a  person  or organization described in PHIPA that has custody or control of Personal Information
 
Privacy Laws – The Regulated Health Professions Act (RHPA), Schedules attached, Dentistry Act, 1991, Regulations made under these Acts, and By-laws of the College, the Personal Health Information   Protection   Act,  2004   (PHIPA),   t h e   Pe r s o n a l In f o r m a t i o n   Pr o t e c t i o n   an d   El e c t r o n i c   Do c u me n t s Ac t   ( P I P E D A ) ,      An  Act  to  promote   the  efficiency   and adaptability of the Canadian economy by regulating certain activities   that   discourage   reliance   on   electronic   means   of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic   Documents   Act   and   the   Telecommunications   Act (CASL)

Member – A member of the College and includes a health profession  corporation   holding  a  valid  Certificate  of Authorization issued by the College
 
Office – The dental office operated by Dr. Meikle Dentistry Professional Corporation 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 1560 Yonge Street, Suite 290, Toronto, ON M4T 2S9.
 
Patient – An individual about whom our Office collects Personal Information   in  order  to  carry  out  prognosis,   diagnosis,   and treatment, including controlled acts
 
Personal Health Information – Identifying information about an individual  in oral or recorded form, if the information  relates to the physical or mental health of the individual, the provisions of health  care  to  the  individual,  a  plan  of  service,  payment  or eligibility for health care, donation by the individual or any body part or bodily substance of the individual or is derived from the testing or examination of any such body part or bodily substance, or   is   the   individual’s   health   care   number   or   identifies   an individual’s substitute decision maker.  Included in the definition of Personal  Health  Information  is personal  information  such as your name, date of birth, address, health history, or records of referral, when collected and retained in connection with the provision of health services
 
Personal  Information-  Identifying  information  about  an individual, other than business contact information, and includes Personal Health Information
 
Privacy Officer – means the contact person designated in this Privacy and Anti-Spam Code as the agent of our Office authorized on our behalf to, among  other things,  facilitate  our compliance with the Privacy Laws
 
RHPA Procedural Code – The Health Professions Procedural Code, Schedule 2 to the Regulated Health Professions Act (RHPA)
 
Service Providers – means dentists and dental professional corporations providing professional services at the Office in conjunction with Dr. Meikle Dentistry Professional Corporation

Dental Care Kingston, 110 Princess Street, Kingston, Ontario, T:613-546-9898, info@dentalcarekingston.ca
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