Privacy Code
Introduction
Dentistry is a regulated profession in Ontario under the Regulated Health Professions Act, 1991 (RHPA). It is the responsibility of the Royal College of Dental Surgeons of Ontario (the College) to regulate Ontario dentists in the public’s interest.
The College has legal obligations under the RHPA and the Personal Health Information Protection Act, 2004 relating to confidentiality and privacy of the information it collects or otherwise receives in fulfilling its objects and regulatory mandate.
The primary legal obligations for the College are in the RHPA under section 36. This section applies to all individuals who are employed, retained or appointed by the College, including members of College Council or College committees.
College Commitments
In fulfilling its legal obligations the College has made a number of commitments to ensure that information remains confidential and private. Those commitments are as follows.
1. Privacy Officer
The College has a dedicated Privacy Officer who oversees all matters related to confidentiality and privacy.
The Assistant Registrar, Andréa Foti, is the College’s Privacy Officer. Complaints or questions regarding privacy or confidentiality should be directed to her at privacy@rcdso.org.
2. Limiting Collection, Use and Disclosure
The College will only collect, use or disclose information as required or permitted by law.
The RHPA Procedural Code and College By-laws clearly designate the information regarding members that is publicly available and the By-laws can be accessed from the College website at www.rcdso.org.
In addition, under the RHPA Procedural Code, the College is required to publish certain information regarding discipline hearings conducted by the Discipline Committee.
Under the RHPA Procedural Code, discipline hearings conducted by the Discipline Committee are usually open to the public. Evidence at a discipline hearing may include personal information regarding the member and the member’s patients, employers and colleagues related to allegations of professional misconduct or incompetence. Under the RHPA Procedural Code, the panel of the Discipline Committee has discretion to close a hearing under certain prescribed circumstances and/or restrict the publication of personal information where appropriate.
The College maintains and regularly updates a Records Classification Scheme and Retention Schedule.
3. Accuracy
The College uses its best efforts to ensure that the information it collects, uses, discloses, or retains is accurate.
Dentists are required to provide the College with current name, contact and employment information and to advise the College of changes within ten (10) days of any change. This information is updated on the public register within 24 hours of the College receiving this information and when members renew their registration with the College.
4. Safeguards
The College ensures that information it holds is secure.
The College employs multi-layer security systems to protect electronic data within the College’s infrastructure, as well as policies on security for mobile devices and email encryption. Other security measures include restricting access to information to authorized personnel, ensuring that physical files are under lock and key, encrypting digital files for transfer off-site, and managing Committee materials centrally. The College reviews its security measures regularly to ensure that all information is secure.
Employees of the College receive an orientation and ongoing training regarding the information safeguards required for information and their importance. Council members and committee members receive orientation as to their obligations to maintain confidentiality.
The College ensures that information that is no longer required to be retained is disposed of in a secure manner.