Privacy of personal information is an important principle to Emerald Dental Works Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and 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, ethnic background, family status), their health (e.g., health history, oral health condition, health services and devices received by them) or their activities and views (e.g., a person’s self-image, religion, politics, opinions expressed by an individual, 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, Emerald Dental Works Inc., includes at the time of writing three dental technologists and two technicians. 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 computer consultants, laboratory security and maintenance workers, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, website managers, premises cleaners and lawyers. 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 dental laboratories, we collect, use and disclose personal information in order to serve our patients. For our patients, the primary purpose for collecting personal information is to provide dental laboratory services. For example, we collect information about a patient’s health history, including physical and oral health condition and function and social situation in order to help us assess what their oral health needs are, to advise them and/or their dentists of their options and then to provide the health care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing oral health services we can identify changes that are occurring over time. It would be rare for us to collect such information without the patient’s implied consent (generally provided by the dentist), but this might occur where we believe the patient would consent if asked and it is impractical to obtain consent (e.g., a dentist sends a prescription on behalf of the patient and we have no reason to believe that the patient is unaware of the process).
Our dental laboratory may collect, use and disclose personal information about clients, such as referring dentists, denture therapists, and other laboratories, in order to contact them for providing services (e.g., calling a dentist at a home number) or to make them aware of changes or developments in our laboratory (e.g., new products or services) or normal promotional activities (e.g., delivering small gifts). We try to use business contact information whenever possible. Generally the client will provide this information to us and it will be apparent from the circumstances how the information will be used. If a client objects to the use of personal information it shall be immediately deleted from our files or, where agreed to be kept on file, will not be used for that purpose again.
About Members of the General Public
For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar or conference) or to make them aware of dental laboratory services in general or our laboratories in particular. For example, 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 reason, possible (e.g., we did not know that it was a home address), we will upon request immediately remove any personal information from our distribution list.
On our website we only collect, with the exception of cookies, 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). Cookies are only used to help you navigate our website and are not used to monitor you.
About Contract Staff, Volunteers and Students
For people who are contracted to do work for us (e.g. temporary workers and consultants), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out pay cheques, 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 the case of a health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur in the laboratory). 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: RELATED AND SECONDARY PURPOSES
How do we collect your personal data?
We use different methods of data information from and about you through:
- Direct Interaction – We collect your Identity, Financial and Contact Information by filling out the forms or by coordinating with us by either post, phone or email. This happens when:
- a person applies for our services and products
- subscribes to our email list
- giving us feedback via forms (ie. web or written)
- purchasing a product
- Automated Interaction –We collect information about your technical data about your equipment, and location. We collect this data using cookies, server logs and other technologies.
- Third party or publicly available sources – We also receive data about you from various third-party program and public sources.
- Online Interactions
- Google Analytics
- Campaign Monitor
- Physical Interactions
- Financial, Contact and Transaction Data from providers of delivery services.
- Online Interactions
Usage of your Data
Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
- To invoice clients or patients for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
- To advise clients or patients that their product or service should be reviewed (e.g., to ensure a product is still functioning properly and appropriately for their then current needs and to consider modifications or replacement).
- To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service, arrival of a new product) that we have available.
- Our laboratory reviews patient 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 improvement reviews of our Laboratories, including reviewing client and patient files and interviewing our staff.
- Dental Technologists are regulated by the College of Dental Technologists 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 obligations. Sometimes these reports include personal information about our clients, patients, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada 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 the organization to patients is paid for by third parties (e.g., OHIP, WSIB, private insurance). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate patient entitlement to this funding.
- Clients, patients, 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 patients over a period of months or years for which our previous records are helpful. We retain our patient information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services (our regulatory College also requires us to retain our patient records).
- If Emerald Dental Works Inc. or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the Laboratory’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 already agreed 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.
- Cookie – browser cookie is a piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. Cookies allow us to calculate the number of people visiting and using our website and which part of our website is more popular. This helps us to gather feedback information to constantly improve our website for a better service to our clients. Cookie do not gather any personal information about you and we do not intentionally store any personal information that your browser provided to us in your cookie.
- E-mail Newsletter – We use your email address via a third-party program to send new information about our company for the knowledge of our clients.
You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities, by paying for your services in advance). You can also unsubscribe from out E-mail Newsletter by simply clicking unsubscribe that is in the bottom page of our E-mail. We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
- Paper information, samples and work product are either under supervision or secured in a locked or restricted area.
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.
- Paper information and samples and devices are transmitted through sealed, addressed envelopes or boxes by reputable companies.
- Electronic information is transmitted either through a direct line or is anonymized or encrypted.
- External consultants and agencies with access to personal information must enter into privacy agreements with us or otherwise provide suitable privacy assurances to us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions 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.
We keep our client and patient files for about ten years. Our client, patient 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 or patients) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a 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.
YOU CAN LOOK AT YOUR INFORMATION
Every client has the right to obtain their personal information from our Information Officer. Our clients also have the right to rectification of inaccurate personal data concerning our client, right to erasure of information but this does not apply if processing is necessary. 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 there is a problem we may ask you to put your request in writing. 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 we have about you, 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 to substantiate 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?
Our Information Officer, Karen Bradbury, can be reached at:
71 Emerald St. South | Hamilton, ON | L8N 2V4
PHONE (905) 527-1422 or 1- (800) 263-2113
She 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. She 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.
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. However, if we cannot satisfy your concerns, you are entitled to complain to our regulatory body:
COLLEGE OF DENTAL TECHNOLOGISTS OF ONTARIO
College of Dental Technologists of Ontario
2100 Ellesmere Road, Suite 260
Scarborough, ON, M1H 3B7
1-877-391-CDTO (Within Canada)
Fax: (416) 438-5004
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 principals that are too detailed to set out here. There are some rare exceptions to the commitments set out 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 also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 KENT STREET | OTTAWA, ONTARIO | K1A 1H3
PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376 | FAX (613) 947-6850 |
TTY (613) 992-9190 www.privcom.gc.ca