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Horizon Dental Personal Information Protection Policy

At Horizon Dental, we are committed to providing our patients with exceptional service. As providing this service involves the collection, use, and disclosure of some personal information about our patients, protecting that information is one of our highest priorities.

This Personal Information Protection Policy, in compliance with the BC Privacy Information Protection Act (PIPA), outlines the principles and practices we follow in protecting patients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our patients’ personal information and allowing our patients to request access to, and correction of, their personal information.

DEFINITIONS

• “Personal Information” means information about an identifiable individual. Personal information does not include contact information (described below).
• “Contact Information” means information that would enable an individual to be contacted and includes names; home and work addresses; home, cell and work telephone numbers and e-mail addresses.
• “Medical Information” means a patient’s health history, their family health history, current physical condition, and previous dental treatments and experiences.
• “Collection” is the act of gathering, acquiring, or obtaining personal information from any source, by any means.
• “Consent” involves a voluntary agreement with what is being done or proposed. Consent may be express or implicit.
• “Express consent” signifies than an individual, knowing what personal information is being collected and for what purposes, willingly agrees to the information being collected, used and disclosed as notified. It may be given in writing or verbally.
• “Implied consent” exists when an individual is “deemed” to consent to collection, use or disclosure of personal information if the individual voluntarily provides it for a purpose that would, at the time, be considered obvious to a reasonable person.

COLLECTING PERSONAL INFORMATION

Unless the purposes for collecting personal information are obvious and the patient voluntarily provides their 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.

We collect contact information from our patients for the following purposes:

• To open and update the patient file.
• To invoice patients for dental services, to process credit card payments, or to collect unpaid accounts.
• To process claims for payment of reimbursement from third-party health benefit providers and insurance companies.
• To send reminders to patients concerning the need for further dental examination or treatment.
• To send patients informational material about our dental practice.

Contact information is disclosed to third party health benefit providers and insurance companies where the patient has submitted a claim for reimbursement or payment of all or part of the cost of dental treatment or has asked us to submit a claim on the patient’s behalf.

Financial information may be collected in order to make arrangements for the payment of dental services.

For the safety and security of our staff and patients, we collect audio and visual surveillance limited exclusively to the front lobby and outer entrances/exits to our office to minimize potential privacy intrusions. Access to recordings is restricted, stored securely, and destroyed within 30 days unless it may be required as part of a criminal, safety, or CDSBC investigation for evidentiary purposes.

Patients’ Medical Information is collected and used for the purpose of diagnosing dental conditions and providing dental treatment. Patients’ Medical Information may be disclosed to the following:

• To third party health benefit providers and insurance companies where the patient has submitted a claim for reimbursement or payment of all or part of the cost of dental treatment or has asked us to submit a claim on the patients’ behalf.
• To other dentists and dental specialists, where we are seeking a second opinion and the patient has consented to us obtaining the second opinion.
• To other dentists and dental specialists where those dentists have asked us, with the consent of the patient, to provide a second opinion.
• To other health care professional such as physicians if the patient, with their consent, has been referred by us to the other health care professional for either a second opinion or treatment.

We may also use your photos and x-rays for educational or research purposes only. We will not distribute photos or x-rays without your express permission; complete confidentiality will be respected.

STORAGE AND RETENTION OF PERSONAL INFORMATION

Horizon Dental protects personal information by ensuring security safeguards appropriate to the sensitivity of the information are in place, including through the use of the following measures:

• Physical (i.e. locked filing cabinets, restricted access, appropriate security measures when disposing of personal information)
• Organizational (i.e. security clearances, access only on a “need to know” basis)
• Technological (i.e. passwords, firewalls, data disconnection from the internet, and regular backups) and training of employees.
• Proper deletion of digital records.

If we are ever considering selling all or part of our practice, qualified potential purchasers may be granted access to patient information as part of the due diligence process. This is to verify information pertaining to the potential sale. If this occurs, we will take steps to ensure that the prospective purchaser safeguards all personal information.

Patient clinical records are kept by the Practice for 16 years after the last date of treatment, or for 16 years after a minor’s 19th birthday, in accordance with CDSBC standards.

ACCURACY

Horizon Dental will make reasonable efforts to ensure that personal information is as accurate, complete and current as required for the purposes for which it was collected. In some cases, we rely on our patients to ensure that certain information, such as your telephone number, is current, complete, and accurate. From time to time we may contact a patient or guardian to ensure that the information collected is or remains accurate and up-to-date.

RIGHT OF ACCESS

Horizon Dental is open about the policies and procedures it uses to protect personal information. Any inquiries may be made to our Privacy Officer. Upon written request we will, within a reasonable time period, tell the individual what personal information we have, for what purposes it is being used, and to whom it has been disclosed if applicable and within the time period for which records are available. Patients have the right to challenge the accuracy and completeness of their information and have it amended if it is inaccurate, incomplete or out-of-date.

In certain circumstances, the we may refuse to disclose personal information, including:

• where required by law, certain personal information may not be disclosed;
• where the information contains personal information about another individual;
• where the information is of such a nature that its disclosure could reasonably be expected to prejudice the mental or physical health of the individual;
• where the information was gathered in the course of a formal dispute resolution process;
• where the information is subject to solicitor-client or litigation privilege. 

Original dental records compiled by a dentist are the legal property of the dentist. Upon written request, patients have the right to examine and copy their clinical records. Written consent must also be obtained prior to the release of records to a different dental office. Information may be withheld if it contains commercial information that could have the competitive position of the Practice, was collected in regards to an investigation, or could compromise the personal information of another individual.

COMPLIANCE AND CONTACT INFORMATION

In this office, Dr. Cindy Nagel acts as the Privacy Information Officer.  The Privacy Information Officer has three main responsibilities:

1. Encourage compliance with the Practice’s Confidentiality Policy and PIPA
2. Respond to issues related to personal information, including responding to requests for access and correction of personal information
3. Record and document all complaints; work with the provincial information and Privacy Commissioner during an investigation.

Requests for access to information, issues or complaints about the Dental Office’s compliance with this Policy regarding the handling of personal information, and questions or comments about this Policy may be addressed to the Dental Office’s Privacy Officer: Dr. Cindy Nagel via email @drcindy@horizondental.clinic

The individual may also write to the Information and Privacy Commissioner of British Columbia:

Office of the Information and Privacy Commissioner for British Columbia

PO Box 9038, Stn. Prov. Govt. Victoria, BC V8W 9A4

Phone: (250) 387-5629

Fax: (250) 387-1696

Email: info@oipc.bc.ca

This policy may be updated from time to time. Last revision: May 26, 2021