PRIVACY POLICY

Your privacy is important to us. In our ongoing effort to protect your privacy and ensure the confidentiality of your information, we have implemented a Privacy Policy relating to the collection, use, disclosure, and protection of personal information.

ACCOUNTABILITY

Clinique Dentaire Tremblay is responsible for all personal information under its control.

We have appointed Dr. Adrienne Miller as the Privacy Officer responsible for ensuring our compliance with provincial privacy laws in the Quebec Region.

Although other staff may be responsible for the day-to-day collection and processing of your personal information, all staff are briefed and receive training on the importance of your privacy and how to handle your personal information.

We are responsible for personal information in our possession or custody, including information that has been transferred to a third party for processing. We will utilize contractual means to provide a high level of protection for any personal information processed by third parties.

COLLECTION

We collect your personal information directly from you or an authorized person on your behalf. The types of personal health information we collect may include your name, date of birth, health history, and records of the care provided to you. We collect this information to provide you with health care.

PURPOSE

We will identify the purpose for which personal information is gathered prior to, or at the time of collection.

We may collect, use or disclose your personal information for the following purposes:

1. To plan for and provide dental treatment and care
2. To follow-up on treatment, care, and billing
3. To obtain payment for services provided (from you, your private insurer, or other payors)
4. To manage patient accounts
5. To provide continuing education to our staff
6. To conduct quality improvement activities
7. To conduct risk management activities
8. To compile statistics
9. To conduct research to improve our services
10. To comply with our legal and regulatory obligations
11. For other purposes permitted by law

We will collect, use and disclose only as much of your personal information as is needed to achieve these purposes. When you sign a Patient Consent Form, you are deemed to accept our Privacy Policy relating to the collection, use or disclosure of your personal information.

Should your personal information be used or disclosed for a purpose not previously identified, we will make reasonable effort to identify the new purpose prior to its use or disclosure. We will also obtain your consent before your personal information is used or disclosed for any such new purpose. If you are unclear about the purpose for which we collect information, please Contact Us to ask.

CONSENT

Your personal information will only be collected, used, or disclosed with your knowledge and express consent, except in emergencies and other occasions permitted or required by law. Once your consent is obtained, we will not seek your consent again unless the use, purpose or disclosure changes.

When your personal information may be used for previously unidentified purposes, your consent may be sought after the information has been collected but not before use.

With some exceptions, a parent legal guardian may consent on behalf of a child who is less than 16 years of age.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Please Contact Us to withhold or withdraw your consent to the collection, use or disclosure of your personal information.

LIMITING COLLECTION

We limit the collection of personal information to the amount and type of information necessary for the purposes we identify. All information is collected by fair and lawful means.

LIMITING USE, DISCLOSURE, AND RETENTION

Your personal information will not be used or disclosed for purposes other than those for which the information is collected, except with your express consent, or as permitted by law.

Personal information may be processed, used, stored or accessed in other countries and may be subject to the laws of those countries. We will utilize contractual means to provide a high-level of protection for any personal information accessed or processed by third-parties.

We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected. We limit the use of your personal information, and it is not disclosed for purposes other than those for which the information was collected, except with your consent, or as required by law.

Where your personal information is no longer required to fulfill the identified purposes. It will be destroyed, erased, or made anonymous.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information within our organization to specific individuals who require access to perform their duties. Access to personal information is restricted to the following individuals:

1. Dentists and dental hygienists providing treatment
2. Administrative staff involved in appointment scheduling and billing
3. IT personnel responsible for maintaining and securing our information systems
4. Compliance and regulatory personnel responsible for ensuring adherence to privacy laws

Access to personal information is granted on a need-to-know basis and is limited to the extent necessary to fulfill their respective roles and responsibilities within the Clinic.

We may also disclose personal information to third parties in the following circumstances:

5. With your consent
6. To other healthcare providers involved in your treatment
7. To insurance companies for processing claims
8. To regulatory bodies as required by law

We do not sell or rent personal information to third parties.

ACCURACY

We endeavor to keep all personal information under our control accurate, complete and as up-to-date as necessary for the purposes for which it is being used. If information needs to be updated, we will make every effort to update our records and advise others with access to the information of such changes.

If your personal information changes or you believe that the personal information under our control Is inaccurate, please Contact Us to have the information updated or corrected.

SAFEGUARDS

We keep all information safe from loss, theft, unauthorized use, changes, copying or disclosure. When we no longer need your personal information, we take the necessary precautions to destroy the information just as we do while storing it.

Depending on the format in which your personal information is gathered, security measures may include physical precautions such as locking files cabinets, restricting access to cabinets, offices and files, organizational measures such as limiting access on a need-to-know basis, and technological measures such as passwords and encryption.

OPENNESS

We are open and honest at all times, providing you with specific information about our policies and practices regarding the management of your personal information. If you have any questions or concerns, please Contact Us.

INDIVIDUAL ACCESS

It is your right to know what personal information of yours we have and who we have given it to. Upon written request and with reasonable notice, we will provide access to personal information we have in our possession, how it has been used and any third-party disclosures. We may require you to provide us with additional information which will assist in providing an account of the existence, use and disclosure of your personal information.

CHALLENGING COMPLIANCE

You have the right to challenge our compliance with the Personal Information Protection and Electronic Documents Act and the Personal Health Information Protection Act. We have enquiry and complaint procedures in place and will take the appropriate action to correct personal information handling policies and practices.

VISITORS TO OUR WEBSITE

By accessing or using our website, you consent to the terms of this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, please do not access our website or provide us with any personal information.

We regularly make changes to our Privacy Policy. Your continued access of our website following the posting of changes to this Privacy Policy means that you accept and agree to be bound by such changes. Please check this page periodically for any revisions.

WHEN WE COLLECT PERSONAL INFORMATION

Automatic Collection

We may automatically receive certain information when you interact with our website. This includes information such as the type of web browser you use, your operating system, your IP address, and the domain name of the website you visited us from.

Depending on your browser settings, we may store information on your computer in the form of a “cookie.” Cookies are small pieces of data stored on your computer that allow us to recognize your computer when you return to our website. We may also use cookies to deliver content or save information (such as your password so you do not have to reenter it when next you visit). You may turn off your cookies using the features contained in your web browser; however, doing so may prevent you from making full use of some or all of the features of our website.

Information you provide to us

We may collect personal information from you, such as your name, email address and telephone number when you visit our website and contact us with a question or concern.

We do not sell, rent or loan any information.

In an effort to maintain data accuracy, prevent unauthorized access and ensure the appropriate use of information, we have established physical, electronic and managerial procedures to safeguard the information we collect online. Unfortunately, data transmitted over the internet cannot be 100% secure. Since we cannot assure the security of any information transmitted to us, you transfer information to us at your own risk.

Contact Information

If you have any questions, or concerns or want to make a complaint about our privacy practices, please contact our affiliate:

Privacy Officer: Dr. Adrienne Miller

Clinique Dentaire Tremblay

4849 Boulevard Saint-Charles, Pierrefonds, Québec H9H3E4

E-mail: privacy@smilesfirstcorp.com

Please note that in order for our affiliate to carry on its responsibilities to us, your personal information may be collected, used by and disclosed to our affiliate.

The Privacy Officer will investigate each complaint made to us in writing. If a complaint is found to be justified, the Privacy Officer will take appropriate measures, such as amending any policies and practices, if necessary.

You also have the right to complain to the Information and Privacy Commissioner of Quebec at the address below if you have concerns about our privacy practices or how your personal information has been handled:

Commission d’accès à l’information du Québec

Toll-free number: 1 888 528-7741

Email for any information on the laws: informations@cai.gouv.qc.ca

Email from the administrative court (for appeals): cai.communications@cai.gouv.qc.ca

Québec

525, boulevard René-Lévesque Est, bureau 2.36

Québec (Québec) G1R 5S9

Phone: 418 528-7741

Fax: 418 529-3102

Montréal

2045, rue Stanley, bureau 900

Montréal (Québec) H3A 2V4

Phone: 514 873-4196

Fax: 514 844-6170