1170 4th Line Adjala,
WHAT IS PERSONAL INFORMATION?
WHO WE ARE
3. Our organization, Dent-Line of Canada Inc., includes at the time of writing one dental technologist and four support staff. We use a number of consultants and agencies that may, in the course of their duties some have limited access to personal information we hold. These include computer consultants, bookkeepers and accountants, credit card companies, 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
4. Like all dental supply organizations, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purpose for collecting personal information is to provide dental supply services. For example, we collect information about the name, the office address and phone numbers. We may also take notes on our visits in order to provide better services. Our dental supply organization may collect, use and disclose personal information about clients in order to contact them for providing services to make them aware of changes or developments in our organization (e.g. new products or services) or normal promotional activities (e.g. discounts). 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
5. 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 health services in general or our products in particular. For example, while we try to use work contact information where possible, we might collect home address, fax numbers and e-mail 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.
6. 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 e-mail message, to register for a course or catalogue, to subscribe to our newsletter). Cookies are only used to help you navigate our website and are not used to monitor you.
ABOUT CONTRACT STAFF, VOLUNTEERS AND STUDENTS
7. For people who are contracted to do work for us (e.g. temporary workers), 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 paycheques, 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 that we collect such information without prior consent, but it might happen in the case of health emergency (e.g. SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the organization). 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
8. 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:
A. 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.
B. To advice clients that their product or service should be reviewed (e.g. to ensure a product is still functioning properly and appropriate for their then current needs and to consider modifications or replacement).
C. To advice 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.
D. Our organization review clients 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 to audits and continuing quality improvement reviews of our laboratory, including reviewing client files and interviewing our staff.
E. Dent-Line is regulated by Health Canada 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 behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g. improper services). Also, like all organizations, various government agencies (e.g. Canada Customs and 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.
F. Clients 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 clients over a period of months or years for which our previous records are helpful. We retain our clients information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services ( Health Canada also requires us to retain lot numbers and distribution lists)
G. If Dent-Line of Canada Inc. or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the company’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.
A. Paper information and documents are either under supervision or secured in a locked or restricted area.
B. 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.
C. Paper information and documents are transmitted through sealed, addressed envelopes or boxes by reputable companies.
D. Electronic information is transmitted either through a direct line or is anonymized or encrypted.
F. External consultants and agencies with access to personal information must enter into privacy agreements with us or otherwise provide suitable privacy assurance to us.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
11. 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.
12. We keep our clients files for about ten years. Our clients 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) newsletters, seminars and marketing activities for about six months after the newsletter ceases publication or a seminar or marketing activity is over.
13. 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 or formatted. Alternatively, we may send some or the entire client file to the client.
YOU CAN LOOK AT YOUR INFORMATION
14. With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. 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.
15. 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.
16. 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?
17. Our information officer, Peter T. Pontsa, R.D.T, can be reached at:
1170 4th line, Adjala, RR# 1, Lorretto, Ontario, L0G-1L0
Phone: (519)985-3652or e-mail him at email@example.com
18. He will attempt to answer any questions or concerns you might have.
20. If you have a concern about the professionalism or competence of our services or staff we would ask you to discuss those concerns with us. However, if we cannot satisfy your concerns, you are entitled to complain to the privacy commissioner.
21. 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 principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
22. 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 can be reached at: