The Clinique dentaire B. Fabre et associés is aware of its responsibilities with regard to the protection of personal information.
This policy sets out the rules regarding the governance of patient personal information held by the clinic. It is published on the clinic's website.
Annabelle Laurin is designated as the person responsible for the protection of personal information (Privacy Officer) held by the Clinique dentaire B. Fabre et associés. She can be reached by telephone at 450-653-4050 or by e-mail at protection_rp(a)cliniquebfabre.com.
She has received training in the protection of personal information.
In compliance with the law, she receives and handles all requests related to the protection of personal information, regardless of their nature:
The clinic only collects personal information that is necessary for the provision of dental care, and that is required by the laws and regulations governing the practice of dentistry in Quebec and Canada.
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, namely:
The dentist also records the following information in the patient's dental record:
The dentist collects the information contained in the Ordre des dentistes du Québec's confidential medical-dental questionnaire.
For billing purposes, the clinic may also collect the patient's health insurance number, health insurance card expiry date, name of insurance company, last-resort financial assistance status, and so on.
In the case of a financial agreement signed with the patient, the clinic collects the credit card number, expiry date and name of the cardholder, which it retains for the duration of the agreement in question.
Personal information is collected from the person concerned prior to the first episode of care, using the confidential medical-dental questionnaire.
The personal information of a minor under the age of 14 is collected from the person with parental authority or the guardian.
The personal information of a minor aged 14 or over is collected, at the minor's option, from the minor himself or herself, or from the person with parental authority or the tutor.
The personal information of a person of full age who lacks legal capacity is collected from the tutor or mandatary.
At the time of the initial collection of personal information, and thereafter upon request, the patient or his or her legal representative is informed in clear and simple terms using the form entitled "The clinic informs you" of the following elements:
All clinic employees, including interns and students where applicable, have signed a confidentiality agreement.
All of the clinic's professionals, employees, trainees and students are familiar with this policy, and have benefited from privacy training and awareness activities at a corporate seminar held on September 15, 2023.
Patients' personal information is recorded in the dental record.
Dental records (active and archived) are kept in a locked room to which the public does not have access.
Digital records benefit from additional safeguards to restrict access to authorized persons only (encryption, password-controlled access privileges based on responsibilities, secure off-site daily archiving).
The Privacy Officer validates daily the report of consultations and uses of health information from the dental software.
In accordance with the law, a Privacy Impact Assessment (PIA) is carried out for any project involving the acquisition, development or redesign of an information system or the electronic delivery of services involving the collection, use, disclosure, retention or destruction of personal information.
The law defines "technological product or service" as any equipment, application or service required to collect, store, use or disclose information, such as an information bank or system, a telecommunications network, a technological infrastructure, software or a computer component of medical equipment.
A PIA is also carried out when personal information is to be disclosed to a partner/supplier outside Quebec, and only if the assessment shows that the information would benefit from adequate protection, particularly with regard to generally recognized privacy principles, will it be transmitted, and after informing the person(s) concerned.
Patient personal information may not be disclosed to third parties without the patient's consent, except as provided by law.
To exercise any of the rights set out in this section, the patient must send a detailed request in writing to Annabelle Laurin at protection_rp(a)cliniquebfabre.com. Upon receipt of the request, the patient will receive an acknowledgement of receipt.
In the event of refusal of a request, the Privacy Officer shall state the reasons for the refusal to grant the request and indicate the provision of the law on which the refusal is based, the remedies available and the time limit within which they may be exercised.
If the patient requests access to his or her dental record, the Privacy Officer will provide free access to the dental record within 30 days of receipt of the request and during the clinic's regular business hours.
The patient has the right to:
If the patient makes a request of this nature, the Privacy Officer will respond within 30 days of receipt, and, as the case may be, will issue the patient with a copy of the document or part of the document attesting to the correction or deletion of the information, or an attestation that the patient's written comments have been placed in the file.
Patients have the right to obtain a copy of their dental records. A fee may be charged for reproduction or transmission, and the patient will be advised of the approximate cost. Copies of paper records will be delivered by hand or sent by registered mail.
When the file is on digital media, it will be communicated to the applicant in a structured, commonly used technological format, via a secure transmission method.
The patient has the right to restrict access to his or her health information or to refuse that information concerning him or her be made available to certain specified persons, in certain circumstances.
Patients have the right to file a complaint regarding the collection, use or disclosure of their personal information to a third party, or for any other reason related to the protection of their personal information.
The complaint must contain all the details needed to understand the situation, the person involved, his or her position, the date of the alleged events, the presence of witnesses and their names, if any.
The person responsible for protecting personal information will investigate the matter and meet with all those involved.
All employees and self-employed workers of the dental clinic are required to cooperate in the investigation process, and to do so in the strictest confidence, except to the extent necessary to analyze the complaint.
At the end of the investigation, a report will be produced by the person responsible for the protection of personal information. The report will establish whether the allegations are well-founded and, if so, will make recommendations that may include administrative or disciplinary measures, the implementation of measures to prevent the recurrence of similar incidents, a report to the Commission d'accès à l'information, depending on the nature of the incident, or any other measure deemed appropriate.
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.
The law defines "privacy incident" as :
When the Privacy Officer becomes aware of a privacy incident involving Personal Information, the Privacy Officer shall:
When assessing the risk of harm to an individual whose personal information is affected by a confidentiality incident, the Privacy Officer shall consider, in particular, the sensitivity of the information concerned, the apprehended consequences of its use and the likelihood that it will be used for harmful purposes.
When the incident presents a risk of serious prejudice, the Privacy Officer must, with due diligence, notify the Commission d'accès à l'information using the form provided by the Commission for this purpose, as well as any person whose personal information is affected by the incident. It may also notify any person or organization likely to reduce this risk, by communicating only the personal information required for this purpose without the consent of the person concerned.
Dental records are kept for five years following the last entry or insertion in the record, in accordance with the law.
Personal information relating to supporting documents required to verify information contained in the clinic's records and books of account 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, using the following methods:
Policy approved on 2023-09-20 by Eva Bedkowska Fabre, DMD, President
Through its Web site, Clinique dentaire B. Fabre et associés collects personal information about you.
When you connect to our Web site, certain personal information is exchanged between your computer and our server. This exchange is necessary so that the data contained on our site can be correctly communicated to the computer equipment you are using. This personal information is kept by the clinic solely for technical and statistical purposes related to the performance of our website.
This information includes:
The clinic does not store any cookies permanently. Only a temporary cookie is used during your visit to our site to improve the performance of certain features.
You can deactivate cookies via your web browser. However, this deactivation may have the effect of restricting certain functionalities of our website.
Personal information that you voluntarily provide to us by e-mail or via the appointment forms (regular and emergency) on our website, such as your name and e-mail address, will only be used to enable clinic staff to respond to you or your request, and will then be deleted.
All clinic employees have signed a confidentiality agreement.
If you have any questions about this policy, or if you have any complaints about non-compliance with it, please contact Annabelle Laurin in writing at protection_rp(a)cliniquebfabre.com.