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 others
besides the dentist or the dentist’s staff.
Legislation – The Regulated Health Professions
Act (RHPA), Schedules attached, Dentistry Act, Regulations made
under these Acts, and By-laws of the College, and the Personal Information
Protection and Electronic Documents
Member – A member of the Royal College of Dental
Surgeons of Ontario and this includes a health profession corporation
Office – The dental office and when referencing
access to information, to the Privacy Information Officer, and the
Patient – An individual about whom the dentist collects personal
information in order to carry out prognosis, diagnosis, andtreatment,
including controlled acts
Personal Information – Information about a
patient that is recorded in any form, and this includes: the patient’s
name, address, telephone number, social insurance number, fax number,
e-mail address, gender, marital status, children, date of birth,
occupation, medical records, health records, insurance company,
insurance coverage, history, occupation, place of work, employer
RHPA Procedural Code - The Health Professions Procedural
Code, Schedule 2 to the Regulated Health Professions Act (RHPA)
Principle 1: Accountability
The dentist in this office is responsible for information collected
by him/her, or under his/her direction, and under his/her control.
Accountability for this office’s compliance
rests with the designated individual or individuals, even though
others in the office may be responsible for the day-to-day collection
and processing of personal information.
The identity of the individual designated by the
dentist to oversee the compliance, the Privacy Information Officer,
will be made known upon request.
This office is responsible for information in our
possession or custody, including information that has been transferred
to a third party for processing. We will use contractual or other
means to provide a comparable level of protection while the information
is being accessed and/or processed by that third party.
Our office will implement policies and practices
to give effect to the principles, including:
- implementing policies to protect personal
- establishing procedures to receive and respond
to complaints and inquiries;
- training staff about privacy policies and practices;
- developing information to explain privacy policies
Principle 2: Identifying
Purposes for Collecting Information
The purposes for which personal information is collected in this
office will be identified before or at the time
the information is collected.
This office collects personal information for the
- to deliver safe and efficient patient care
- to identify and to ensure continuous high quality
- to assess your health needs
- to provide health care
- to advise you of treatment options
- to enable us to contact you
- to establish and maintain communication with
- to offer and provide treatment, care and services
in relationship to the oral and maxillofacial complex and dental
- to communicate with other treating health-care
providers, including specialists and general dentists who are
the referring dentists and/or peripheral dentists
- to allow us to maintain communication and contact
with you to distribute health-care information and to book and
- to allow us to efficiently follow-up for treatment,
care and billing
- for teaching and demonstrating purposes on an
- to complete and submit dental 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 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 Royal College of Dental
Surgeons of Ontario, including the delivery and/or review of patients’
charts and records to the College in a timely fashion for regulatory
and monitoring purposes
- to permit potential purchasers, practice brokers
or advisors to evaluate the dental practice
- to allow potential purchasers, practice brokers
or advisors to conduct an audit in preparation for a practice
- to deliver your charts and records to
the dentist’s insurance carrier to enable
the insurance company to assess liability and quantify damages,
- to prepare materials for the Health Professions
Appeal and Review Board (HPARB)
- to invoice for goods and service
- to process credit card payments
- to collect unpaid accounts
- to assist this office to comply with all
- to comply generally with the law
This office will identify the purposes for which
personal information is collected, at or before the time of collection.
We will only collect that information necessary for the identified
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 the disclosure.
Your consent is required before the information can be used or disclosed
for that purpose.
Office staff collecting personal information will
be able to explain to you the purpose for which the information
is being collected.
When you sign the Patient Consent Form, you will
be deemed to understand and accept this office’s collection,
use and disclosure of your information for the specified purposes.
Principle 3: Consent
This office will seek informed consent for the collection, use and/or
disclosure of personal information, except where it might be inappropriate
to obtain your consent, and subject to some exceptions set out in
Consent is required for the collection of personal
information and subsequent use or disclosure of that information.
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 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.
Existing protocols for electronic submissions of
dental claims require a signature on file. Specific consent may
be required for additional requests from insurers. This shall be
collected at the time, or in conjunction, with predeterminations
for extensive services, providing the scope of information released
is disclosed. If there is any doubt, information shall be released
directly to you for review and submission.
Consent for the collection, use and disclosure of
personal information may be given in a number of ways, such as:
- signed medical history form;
- signed introductory questionnaire;
- taken verbally over the telephone and then charted;
- written correspondence.
You may withdraw consent upon reasonable notice.
Principle 4: Limiting Collection
of Personal Information
The collection of personal information by our office shall be limited
to that which is necessary for the purposes identified in
this Privacy Code.
Principle 5: Limiting Use, Disclosure and
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 by law.
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
the College’s Guidelines on Dental Recordkeeping.
Principle 6: 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 shall
be accurate, complete and up-to-date will depend upon the use of
the information, taking into account the interest of our patients.
Information shall be sufficiently accurate, complete and up-to-date
to minimize the possibility that inappropriate information
is used to make a decision about you as our patient.
Principle 7: Safeguards for Personal Information
Our office has taken appropriate measures to safeguard your personal
information from unauthorized access, disclosure, use or tampering.
Safeguards are in place to protect your personal
information against loss or theft,
as well as unauthorized access, disclosure, copying, use or modification.
Your information is protected, whether recorded on
paper or electronically.
Our office staff are aware of the importance of maintaining
the confidentiality of personal information.
Care is used in the care and destruction of personal
information to prevent unauthorized access to the information
even during disposal and destruction.
Principle 8: 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:
- a Patient Information Sheet that outlines the
name of the Privacy Information Officer who is accountable for
our office privacy policies. This is the person to whom you can
direct any questions or complaints. The Information Sheet also
describes how to access your personal information held in this
- a copy of our Patient Consent Form that explains
how this office collects, uses and discloses your personal information;
- our office Privacy Code
Principle 9: 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 that information.
Upon written request and with reasonable notice,
our office will advise you whether
or not we hold personal information about you.
Our office shall allow you access to this information.
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
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
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
The dentist will comply with the regulations of his/her
College that define patient access to records.
You are free to challenge the accuracy and completeness
of the information and seek to have it altered, amended, or changed.
This process is explained in the Patient Information Sheet.
When a challenge is not resolved to your satisfaction,
we will record the substance of the unresolved challenge.
When appropriate, the existence of the unresolved
challenge shall be transmitted to third parties having access to
the 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.
Principle 10: Challenging Compliance
You shall be able to challenge compliance with these principles
with the office’s Privacy Information Officer who is accountable
within the dental office for the dentist’s compliance. Our
office has in place procedures to receive and respond to your complaints
This information, including the name of our office’s
Privacy Information Officer, is included in the Patient Information
Sheet, available on request.
The procedures are easily accessible and simple to
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. This information
is outlined in the Patient Information Sheet.
The Privacy Information Officer in our office will
investigate each and every complaint made to the office in writing.
If a complaint is found to be justified, the Privacy
Information Officer will take appropriate measures, including, if
necessary, amending any office policies and practices.
Patients will be provided with information about
how to contact the Privacy Commissioner of Canada to forward any
unresolved complaint. This information is included in the Patient
Information Sheet, available on request.