PRIVACY CODE FOR THE DENTAL OFFICE
OF DR. STEVE M. ZAJACZ
ZAJACZ DENTAL CENTRE
|
| |
|
INTRODUCTION
|
Privacy of personal information is an important principle in the provision of
quality dental 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. We also try to be as open and transparent
as possible about the way we handle your information.
We have tried to make our office Privacy Code as easy to understand as
possible. To ensure that you see how we are complying with the federal privacy
legislation, the Personal Information and Protection and Electronic Documents Act
(PIPEDA), our Privacy Code is organized to follow the Act's ten interrelated
principles that are the foundation of PIPEDA.
|
|
Back to top
|
|
DEFINITIONS
|
|
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.
|
|
Consent - A voluntary agreement with what is being done, or is being
proposed to be done. This 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 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 Act
(PIPEDA).
|
|
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 dental Office.
|
|
Patient - An individual about whom the dentist collects personal
information in order to carry out prognosis, diagnosis, and treatment, including
controlled acts.
|
|
Personal Information - Information about a patient that is recorded in any
form, 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, heath 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).
|
|
Back to top
|
|
PIPEDA PRINCIPLES
|
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.
The 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 information;
- Establish procedures to receive and respond to complaints and inquiries;
- Training staff about privacy policies and practices;
- Developing information to explain privacy policies and procedures
|
|
Back to top
|
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 following purposes:
- To deliver safe and efficient patient care
- To identify and ensure continuous high quality service
- 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 you
- 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 healthcare 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 healthcare information and to book and confirm appointments
- To allow us to efficiently follow-up for treatment, care and billing
- For teaching and demonstrating purposes on an anonymous basis
- 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 sale
- To deliver your charts and records to the dentist's insurance carrier to enable the insurance company to assess liability and quantify damages, if any
- To prepare materials for the Health Professions Appeal and Review Board (HPARB)
- To invoice for goods and services
- To process credit card payments
- To collect unpaid accounts
- To assist this office to comply with all regulatory requirements
- 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 purposes.
When personal information has been collected and is to be used or disclosed for a
purpose not previously identified, the 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.
|
|
Back to top
|
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 law.
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;
- Email;
- Written correspondence.
You may withdraw consent upon reasonable notice.
|
|
Back to top
|
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.
|
|
Back to top
|
Principle 5: 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 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 Record Keeping.
In destroying personal information, our office has developed guidelines to ensure
secure destruction in accordance with the College's Guidelines on Dental Record
Keeping.
|
|
Back to top
|
Principle 6: Accuracy of Personal Information
This office endeavours to ensure that your personal information is 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.
|
|
Back to top
|
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 is 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.
|
|
Back to top
|
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 office;
- A copy of our patient consent form that explains how this office collects, uses and discloses your personal information;
- Our office Privacy Code
|
|
Back to top
|
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 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.
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.
|
|
Back to top
|
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 or inquiries.
This information including the name of our office's Privacy Information Officer,
is included in the Patient Information Sheet, available on request.
The procedure is 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.
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.
|
|
Back to top
|
|
|