PACIFIC DENTAL SERVICES® LLC
WASHINGTON CONSUMER PRIVACY POLICY
THIS PRIVACY POLICY APPLIES TO OUR SITES, TRUSTED OFFICES, AND APPLICATIONS.
MHMDA Privacy Policy for Washington Residents Last Updated and Effective On: September 30, 2023
This MHMDA Privacy Policy for Washington Residents (“MHMDA Privacy Policy” or "Policy") supplements the information contained in Pacific Dental Services’ (“PDS,” “we,” “us,” or “our”) online privacy policy and applies solely to consumers who are residents of the State of Washington (“consumers” or “you”).
We adopt this notice to comply with the My Health My Data Act of 2023 (“MHMDA”). The MHMDA imposes specific obligations on businesses processing consumer health data of Washington residents. Terms used in this MHMDA Privacy Policy, such as consumer health data, consumers, third party(ies) and processors, have the same meaning as they are defined in the MHMDA. Pursuant to the MHMDA, Pacific Dental Services is required to provide consumers a notice, used before the requesting of consumer health data, that identifies the categories of consumer health data that may be collected, indicates the purpose of such collection, and provides the consumers rights related to such information.
Notice Before Requesting Collection
Before the request of collection, you have a right to receive notices of our practices, including the categories of personal and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained. You can find those details below. Additionally, in order for us to collect the information, you must affirmatively opt-in and consent to the collection of your consumer health data.
What is Consumer Health Data?
The MHMDA provides consumer health data rights to Washington residents. The MHMDA defines consumer health data as “personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status.” Consumer health data does not include personal information used to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws and is approved, monitored, and governed by an institutional review board, human subjects research ethics review board, or a similar independent oversight entity that determines that the regulated entity or the small business has implemented reasonable safeguards to mitigate privacy risks associated with research, including any risks associated with reidentification. “Personal information” is defined as information that “identifies or is reasonably capable of being associated or linked, directly or indirectly, with a particular” Washington consumer or household. Personal information does not include publicly available information or consumer information that is deidentified.
Categories of Consumer Health Data We Collect About You
We collect or generate consumer health data about you in a number of ways depending on the product or service and the relationship we have with you. For example:
We require this information to understand your needs and provide you with a list of dental offices for relevant referrals. Once you have selected a new dentist, we will share your information with your dentist.
For more information, see below for a list of the categories of consumer health data/personal information, along with some descriptions and examples that we may collect through each of the processes described above:
The Purposes for Which Your Consumer Health Data is Collected or Used
We use your consumer health data and personal information for the following business purposes:
Any information collected is disclosed to you here and is used as permitted or required by law. We also abide by the set of rules prescribed to us by Google AdWords: https://support.google.com/adwordspolicy/answer/143465.
We may also use your consumer health data and personal information for any other purpose that we disclose at the time you provide, or when we collect, your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.
We are required to identify the categories of personal information we share with third parties for operational purposes. We disclose the following categories of personal information for operational purposes: personal identifiers; device and online identifiers and related information; demographic information; internet, application, and network activity; location data; sensory (audio data).
The Source of The Consumer Health Data We Collect About You
Sharing of Your Consumer Health Data
We share consumer health data as set forth below:
Selling of Your Consumer Health Data
We cannot sell your consumer health data without a valid authorization from you. Under the MHMDA this valid authorization must be retained for six (6) years. Such authorization must include the following:
Amount of Time Your Consumer Health Data is Retained
We retain consumer health data for various periods depending on the nature of the health data, the purposes for its collection and use, and based on our legal and ethical obligations. Generally, we retain data only for so long as necessary to fulfill the purposes for which we collected it. To determine the appropriate retention period for consumer health data, we consider the amount, nature, and sensitivity of the consumer health data; the potential risk of harm from unauthorized use or disclosure of your consumer health data; the purposes for which we process your consumer health data and whether we can achieve those purposes through other means; and the applicable legal requirements.
Rights to Your Consumer Health Data
You have a number of legal rights when it comes to your Consumer Health Data under the MHMDA. Without being discriminated against for exercising these rights, you have the right to request that we disclose what consumer health data we collect from you, the purposes for which we disclose your consumer health data, the right to request that we delete that information, and the right to not allow the sale or sharing of your consumer health data, subject to certain restrictions, by not opting-in.
Right to Confirm
You have the right to confirm what categories of your consumer health data we collect, use, or sell and the purposes for which the data is disclose. You may request access to the specific pieces of consumer health data that we collect from you. (“Right to Confirm”)
Right to Obtain
You have the right to obtain a list of all third parties and affiliates with whom we have shared or sold consumer health data. You also have the right to obtain an active email address or another online mechanism used to contact each third party. (“Right to Obtain”)
Right to Withdraw Consent
You have the right to withdraw your consent to our collection of your consumer health data. (“Right to Withdraw Consent”)
Right to Delete
You have the right to request that we delete your consumer health data. (“Right to Delete”)
How to Exercise Your Rights
To exercise any of your rights under the MHMDA above, please submit a MHMDA request form or call 888-508-2033.
How Will You Verify My Identity If I Make a MHMDA Request?
In order to verify your identity, we will collect your:
We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identity verification service.
We cannot respond to your request or provide you with consumer health data if we are not able to verify your identity or authority to make the request or confirm the consumer health data relates to you.
You are not required to have an account with us to make a verifiable request.
Contact, Questions or Complaints
We take your privacy seriously and invite you to contact us at the email address below also with any further questions or concerns you may have regarding your privacy or our collection, storage and use of your Consumer Health Data:
Email: privacy@pacden.com