Privacy Policy2018-03-22T10:07:48+00:00

Privacy Policy

Spencer Dentistry values the relationship it has with its patients and is committed to the protection of their personal information. Accordingly, Spencer Dentistry, its employees and volunteers adhere to this Privacy Policy, which is based on the privacy principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (PIPEDA). “Personal Information”, as used in this Privacy Policy, is information about a specific, identifiable individual, but does not include the name, title or business address or telephone number of such individual. In some cases, Spencer Dentistry may set policies about releasing to the public information that is not considered Personal Information, in which case, Spencer Dentistry, its employees and volunteers will be bound by such policies. Spencer Dentistry may set policies about releasing Personal Information about patients with their permission and in accordance with PIPEDA.

 

  1. Accountability – Spencer Dentistry is responsible for all Personal Information under its control and has designated an individual or individuals who are accountable for the office’s compliance with the following principles.
    Many individuals within Spencer Dentistry have the responsibility for the day-to-day collection and processing of Personal Information. Therefore, all employees will comply with this Privacy Policy. Spencer Dentistry is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. It will use contractual or other means to provide a comparable level of protection for information being processed by a third party.
  2. Identifying Purpose – Spencer Dentistry will identify and document the purposes for which it collects, uses, or discloses Personal Information at or before the time of collection. Spencer Dentistry collects, uses, and discloses Personal Information concerning its patients for the following purposes: a) Providing products, services and information of interest to its patients or b) Exchanging information with insurance companies, dental specialists and other dental-related organizations in order to facilitate the provision of products, services and information of interest to its patients. Spencer Dentistry will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the Personal Information is collected, either at the time of collection or after collection, but before use. Spencer Dentistry will identify any other purposes which may arise for the collection, use or disclosure of Personal Information at or before the time the Personal Information is collected. If a new purpose arises in respect of Personal Information already collected, Spencer Dentistry will identify the new purpose prior to the use or disclosure of the Personal Information.
  3. Consent – Spencer Dentistry will collect, use, or disclose Personal Information only with the knowledge and consent of the individual, except in emergencies and on other occasions permitted or required by law, or where appropriate. The way in which Spencer Dentistry seeks consent, including whether it is express (i.e. explicit verbal, written or other authorization) or implied (i.e. can reasonably be determined through the actions or inaction of the individual), may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual can withdraw consent at any time, subject to legal restrictions and reasonable notice. Spencer Dentistry will inform individuals of any implications of withdrawing consent. Typically, Spencer Dentistry will seek consent for the use or disclosure of information at the time of collection. In certain circumstances, such as a proposed use of information for new purposes not previously identified, consent may be sought after the information has been collected, but before use. In certain circumstances, as permitted or required by law, Spencer Dentistry may collect, use, or disclose Personal Information without the knowledge or consent of the individual. These circumstances include Personal Information:a. that for legal, medical, or security reasons makes it impossible or impractical to seek consent;
    b. which is publicly available;
    c. where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way;
    d. which is required to investigate a breach of an agreement or a contravention of a law;
    e. required to act in an emergency that threatens the life, health, or security of an individual;
    f. for debt collection; or to comply with a subpoena, warrant or court order;
    g. for the detection and prevention of fraud or for law enforcement where seeking the consent of the individual might defeat the purpose of collecting the information; or
    h. when the individual is a minor, seriously ill, or mentally incapacitated;
  4. Limiting Collection – Spencer Dentistry will limit the amount and type of Personal Information collected to that which is necessary for identified purposes and will only collect Personal Information by fair and lawful means.
    Spencer Dentistry will collect information in a straightforward and honest fashion. Spencer Dentistry will not coerce, threaten, or mislead individuals into providing Personal Information, nor collect information without individual consent or knowledge, nor gather from other people, such as family members, work colleagues, or acquaintances, without the knowledge and consent of the individual, except in the most compelling circumstances, or for the purposes such as law enforcement. To the maximum extent possible, Spencer Dentistry will identify personal information sources to ensure maximum fairness and openness in information collection practices.
  5. Limiting Use, Disclosure and Retention – Spencer Dentistry will not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Spencer Dentistry will retain Personal Information only as long as necessary to fulfill the identified purposes.
    Spencer Dentistry will retain Personal Information which has been used to make a decision about an individual long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any resource an individual may have under the law.
    When Personal Information is no longer required to fulfill the identified purposes, Spencer Dentistry will destroy, erase, or make it anonymous. Spencer Dentistry will inform individuals of its retention period and what it intends to do with the information after the maximum retention periods are reached.
  6. Accuracy – Spencer Dentistry will use its best efforts to ensure that Personal Information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Spencer Dentistry will use its best efforts to ensure that Personal Information that is used on an ongoing basis, including information that is disclosed to others, and information that is used to make a decision about an individual is accurate, complete, and up-to-date.
  7. Security – Spencer Dentistry will protect Personal Information with safeguards appropriate to the sensitivity of the information.
    Spencer Dentistry will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification regardless of the format in which the information is held. Spencer Dentistry will make its employees aware of the importance of maintaining the confidentiality of Personal Information, and will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information. Depending on the format of the Personal Information, security measures may include physical precautions such as locking file cabinets and restricting access to cabinets, offices and files, and technological measures including passwords and encryption.
  8. Openness – Spencer Dentistry will make specific information about its policies and practices regarding the management of Personal Information readily available, except to the extent that it is confidential commercial information.
    Specifically, Spencer Dentistry will publicize information about:
    a. how to obtain details of the Personal Information held on file for identified individuals;
    b. the type of Personal Information held by Spencer Dentistry, including general account of its use;
    c. general information concerning its Privacy Policy and related policies and procedures; and
    d. what Personal Information is made available to related companies
  9. Individual Access – Upon receipt of a written request, Spencer Dentistry will inform an individual of the existence, use and disclosure of his or her Personal Information and will give the individual access to that Personal Information, which may be challenged and corrected, depending on the circumstances. Spencer Dentistry will respond to all individual written requests within a reasonable time, usually about ten (10) business days, depending upon the complexity of the request and the information, and will assist any individual who informs Spencer Dentistry that he or she needs assistance in preparing a request. Spencer Dentistry may require an individual to provide additional information which will assist it in providing an account of the existence, use, and disclosure of Personal Information. In certain situations, Spencer Dentistry may refuse a request or restrict access to all the Personal Information it holds about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. The reasons for denying or restricting access will be provided to the individual upon request, where permitted by law, and may include:
    a. information containing references to other individuals;
    b. confidential commercial information;
    c. information by its nature must remain confidential;
    d. information collected in the course of investigating a breach of an agreement;
    e. information collected in the course of a dispute resolution process;
    f. information that is subject to solicitor-client privilege; or
    g. any portion of information which for, one or more of these reasons may not be readily severable from the information as a whole
  10. Challenging Compliance – Any individual may address a written challenge concerning Spencer Dentistry’s compliance with its Privacy Policy to Spencer Dentistry’s Office Manager. Spencer Dentistry will investigate all written complaints. Should it find that a complaint is justified, Spencer Dentistry will take all appropriate steps to correct the information and amend the policy or practice as required, and will notify the individual about the outcome.

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