Privacy Policy
Archambault & Morton Orthodontists is aware of its responsibilities with respect to the protection of personal information. This policy sets out the rules governing the governance of patient personal information held by the clinic.
1.0 The person responsible for personal information and their role
Dr. Paul Morton, as the person with the highest authority within the company, is the person responsible for the protection of personal information held by the Archambault & Morton Orthodontists Clinic.
He can be reached at 450.218.1892 or in writing at [email protected]
The Privacy Officer has received training on the protection of personal information.
1.1 Its role
The Privacy Officer receives and processes any request related to the protection of personal information, regardless of its nature, including:
• It receives and processes requests for access, rectification and copies of files
• It ensures the management of confidentiality incidents
• Maintains a record of confidentiality incidents2
• It notifies data subjects of confidentiality incidents that pose a risk of serious harm
• He declares to the Commission d’accès à l’information incidents of confidentiality that present a risk of serious harm
• He can make recommendations related to the protection of personal information
• It may propose the holding of training activities on the protection of personal information
ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
2.0 Personal Information Collected
The clinic only collects personal information that is necessary for the provision of dental care, and required by the laws and regulations governing the practice of the profession of dentistry.
2.1 What personal information does the clinic collect
The clinic collects the personal information listed in sections 15 and 16 of the Regulation respecting the keeping of offices and records and the cessation of practice of members of the Ordre des dentistes du Québec:
• Name
• First name
• Address
• Phone number
• Gender
• Patient’s medical and dental history
The dentist records the following in the patient’s dental record:
• The date of consultation
• Diagnosis
• Treatment choices and prognosis for each person
• The record of operations and the description of all forms of processing carried out
• The materials and medications used to perform the treatment
• Written prescriptions for medication or treatment
• Significant elements of any verbal or written communication with or about the patient
• Examination results, diagnostic elements and radiological examination reports, as well as all models
• Annotations relating to information provided to the patient relating to the acceptance of the treatment and annotations relating to the receipt of the patient’s consent to this treatment
• The name, concentration and quantity of products used in the case of general, regional, local or conscious or deep sedation anaesthesia
• Information and recommendations provided to the patient regarding a treatment
• The date the patient was referred to a health care professional, the name of the health care professional, the purpose of the consultation and the report issued as a result of the consultation
• Annotations, correspondence and any other documents relating to the services rendered by the dentist and any copies of documents or certificates issued to the patient
ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
• Information about professional fees and any amounts charged to the patient
• A note signed by the patient or by his representative, when he has requested the removal of a piece or document, indicating the nature of the document and the date of its withdrawal
The dentist collects the information contained in the confidential medical-dental questionnaire of the Ordre des dentistes du Québec. For billing purposes, the dentist also collects the health insurance number, the expiration date of the health insurance card, the name of the patient’s insurance company, the status of a last-resort financial assistance provider, etc.
2.2 By what means and from whom are they collected?
Personal information is collected from the individual concerned during the first episode of care through the confidential medical-dental questionnaire.
The personal information of a minor under the age of 14 is collected from the holder of parental authority or guardian.
The personal information of minors 14 years of age and older is collected from the minor himself or herself or from the person with parental authority or guardian.
The personal information of the incapacitated adult is collected from the guardian or mandatary. At the time of initial collection of personal information, and thereafter upon request, the patient or his or her legal representative is informed in simple and clear terms using the form entitled “The clinic informs you” 7 of the following:
(1) the name of the body that collects the information
(2) the purposes for which the information is collected
(3) the means by which the information is collected
(4) the rights of access to and rectification of information
(5) the possibility of restricting or refusing access to the information and the terms and conditions (6) the right to withdraw consent to the disclosure or use of the information collected
7° the period for which this information is kept.
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ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
3.0 Safeguards for Personal Information Collected
3.1 Who within the company has access to the personal information collected
Professionals, employees, trainees, or students of the clinic have access to patients’ personal information only to the extent necessary for the performance of their duties.
Treating health care staff and the staff who assist them (dentist, dental hygienist, dental assistant) have access to the health information necessary for the provision of dental care
Administrative staff (e.g., secretary, receptionist, accountant, coordinator) and dentist have access to the information necessary for invoicing, appointment scheduling, and other administrative information.
All clinic employees, including interns and students if applicable, have signed a confidentiality agreement.
All professionals, employees, trainees and students of the clinic have been aware of this policy, and have benefited from training and awareness activities on the protection of personal information (indicate which ones, e.g., webinar, meeting, etc.)
3.2 Location of storage and security measures to ensure the protection of personal information
Patients’ personal information is recorded in the dental record.
The dental record is kept in a cabinet to which the public does not have access. Digital files benefit from protection measures that restrict access to authorized persons only.
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ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
3.3 Logging of Uses of Personal Information
The Privacy Officer shall ensure that the log of uses of health information9 is completed on a daily basis by any staff member or professional who has accessed, used, disclosed or received communication of health information.
3.4 Privacy Impact Assessment
A Privacy Impact Assessment (PIA) is conducted for any project involving the acquisition, development and redesign of an information system or electronic service delivery involving the collection, use, disclosure, retention or destruction of personal information.
The Act defines a “technological product or service” as equipment, application or service required to collect, store, use or communicate information, such as a bank or information system, a telecommunications network, a technological infrastructure, software or a computer component of medical equipment.
A PIA is also conducted when personal information must be communicated to a partner/supplier outside Quebec and it is only if the assessment shows that the information would benefit from adequate protection, particularly with regard to generally accepted privacy principles, that it will be transmitted, and after informing the person(s) concerned.
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ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
3.5 Disclosure to third parties
Patients’ personal information cannot be disclosed to third parties without their consent, except as required by law.
4.0 Patients’ Rights
4.1 Right of access and procedure
If a patient wishes to consult their dental record, they must make a request to Dr. Paul Morton, Privacy Officer, in writing to [email protected].
Upon receipt of the access request, the patient will receive an acknowledgement of receipt. The person in charge of the protection of personal information will give him free access to his file no later than 30 days after receipt of his request, and during the clinic’s usual opening hours.
The Privacy Officer must give reasons for any refusal to comply with an access request by specifying the reasons for the refusal, the provision of the Act on which the refusal is based, the remedies available to the requester, and the time within which they may be exercised.
4.2 Right to rectification of the procedure
The patient has the right to:
(1) to have inaccurate, incomplete or ambiguous information corrected in a document that concerns the person and that is included in any record compiled in respect of the person or if the collection, communication or retention of such information is not authorized by the Act;
(2) to have deleted any information that is out of date or not justified by the subject matter of the file compiled in respect of the applicant;
(3) to include in the file made in respect of the person the comments he or she has made in writing. The request should be addressed to Dr. Paul Morton, Privacy Officer, in writing at [email protected].
The Privacy Officer will respond to the request no later than 30 days after receipt of the document, and will issue a copy of the document or the
ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
a portion of the document attesting that the information has been corrected or removed, or an attestation that the written comments have been placed on file.
The Privacy Officer must give reasons for any refusal to comply with a request for rectification and indicate the provision of the law on which the refusal is based, the remedies, and the time within which they may be exercised.
4.3 Right to obtain a copy and procedure
The patient has the right to obtain a copy of his or her dental record. Requests should be addressed to Dr. Paul Morton, Privacy Officer in writing at [email protected].
The Privacy Officer will respond to the request no later than 30 days after receiving it.
The paper copy of the file will be delivered by hand or sent by registered mail. When the file is computerized, it will be communicated to the applicant in a structured and commonly used technological format, via a secure transmission method.
4.4 Ability to Restrict or Deny Access to Personal Information
Patients have the right to restrict access to their health information or to refuse access to information about them to certain specified individuals, in certain circumstances.
Requests should be addressed to Dr. Paul Morton, Privacy Officer in writing at [email protected].
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ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
4.5 Right to lodge a complaint and procedure
Patients have the right to make a complaint about the collection, use, disclosure to a third party of their personal information, or any other reason related to the protection of their personal information.
Requests should be addressed to Dr. Paul Morton, Privacy Officer in writing at [email protected].
The applicant’s complaint must contain the details necessary to understand the situation, the person accused, his or her position, the date of the alleged events, the presence of witnesses and their names, if any.
Upon receipt of the complaint, the applicant will receive an acknowledgement of receipt. The person responsible for the protection of personal information will investigate, and will meet with all those involved.
Any person employed or self-employed person of the dental clinic is required to cooperate in the investigation process and to do so while preserving the confidentiality of the information in his or her possession, except to the extent necessary to analyze the complaint. At the conclusion of the investigation, a report will be produced by the person responsible for the protection of personal information. It will establish the merits of the allegations and, if necessary, propose recommendations that may include administrative or disciplinary measures, the implementation of measures to prevent future incidents of the same nature from recurring, a declaration to the Commission d’accès à l’information depending on the nature of the incident, or any other measure deemed relevant.
The person responsible for the protection of personal information will inform the complainant in writing of the findings of his or her investigation, and of the measures that will be put in place.
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ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
5.0 Procedure in the event of a confidentiality incident
5.1 Definition
The Act defines a confidentiality incident as:
1. Unauthorized Access to Personal Information by Law
2. Unauthorized use of personal information
3. Disclosure of personal information not authorized by law
4. The loss of personal information or any other breach of personal information.
5.2 Procedure
When assessing the risk of harm to an individual whose personal information is affected by a confidentiality incident, the Privacy Officer must consider, among other things, the sensitivity of the information in question, the anticipated consequences of its use and the likelihood that it will be used for harmful purposes.
When the incident presents the risk of serious harm being caused, the employer must diligently notify the Commission d’accès à l’information using the form provided by the commission for this purpose, as must any person whose personal information is affected by the incident.13 The Minister may also notify any person or organization likely to reduce the risk of limiting the risk of the risk of limiting the risk of the risk of the risk of the person to whom the risk may be described.
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ORTHODONTISTS Dr. Amy Archambault DMD, MSc, FRCD(C) Dr. Paul Morton DDS, MSc, FRCD(C)
6.0 Retention period and destruction
The dental record is kept for five years following the last entry or entry in the record in accordance with the law. Personal information relating to supporting documents necessary to verify the information contained in the clinic’s books and records is retained for six years in accordance with the Income Tax Act. At the end of these periods, personal information will be destroyed in a manner that preserves its confidentiality by the following methods:
• Paper file – (shredder, incineration, etc.)
• Electronic file (digital shredding, shredding, incineration, etc.)
• Models (shredding, incineration, anonymization, etc.)