Playbook, dental clinic

Why a dental record cannot simply be deleted on request

A patient asking a practice to delete everything is usually picturing a mailing list and a mobile number. What they are actually asking about is a clinical record held for a defined period, radiographs and models included, and the erasure right does not override that. The assistant can say so, and it still has to hand the request to a person.

Why this is not the general answer

The handling pattern for data deletion requests holds across every trade. What follows is the part that does not.

  • A dental record is a clinical record with a retention period behind it, so the answer to delete everything is a qualified no with a reason attached, not a description of a process.
  • The record is not only notes: radiographs, clinical photographs, study models and orthodontic casts form part of it, and almost nobody asking for deletion has pictured any of that.
  • Records for a child are usually retained on a different basis from an adult's, running to an age rather than a period from the last visit, and the material has to carry that distinction.
  • The record is also what the practice relies on if care is ever questioned, so a deletion request arriving alongside a complaint has to be recognised for what it is and given to a person at once.

How it arrives

  • delete everything you have about me
  • how long do you keep dental records
  • can i have a copy of my x rays
  • i am moving practice can you delete my file
  • do you keep childrens records for longer
  • who do i send a data request to

What has to be indexed for this to work

Material behind this answer
Your retention schedule for clinical recordsHow long records are kept, measured from what event, and the different basis for children. Quoting a period together with its starting point is what makes the refusal read as a rule rather than as an excuse.
What actually counts as the recordNotes, radiographs, photographs, models, laboratory prescriptions, referral letters and correspondence. Listing them stops the assistant answering as though a record were a row somebody could delete.
What can be changed on requestMarketing preferences, the mobile number used for reminders, a mailing list entry. There is nearly always something you can genuinely act on, and naming it stops the reply being a flat refusal.
How to make a request and who receives itThe address or form, what to include so it can be matched to a patient, and your published response commitment. Route it to an inbox somebody reads, because the clock runs whether or not it was opened.

The reply

A reply worth copying
Dental records are clinical records and we have to keep them for a set period, which our privacy notice sets out along with the different position for children [1]. That includes radiographs and any models, not just the written notes. What we can look at separately is contact details and reminder preferences [2]. I cannot change anything from here, so leave me your name and an email and the request goes to the person who handles them, who will reply within the period in the notice.

It refuses the impossible part with a reason and a citation, so the patient can see this is a rule rather than a preference. It names what is genuinely in the record, since that is the part nobody has considered. Then it offers the part that can move and hands the request over, because a deletion request answered and closed is the characteristic failure here.

Where it stops

The trigger. Any request phrased as deletion or erasure, any request for a copy of records or radiographs, and any request made on somebody else's behalf.

The handover, worded
This is a request rather than a question, so I am passing it to the person who handles them. Leave me your name, an email and a short note of what you are asking for, and you will get a reply within the period set out in our privacy notice.

It stops answering before it guesses, says who will pick it up, and asks for the one thing that makes a reply possible. Nothing about it reads as a dead end.

Never say this here

Out of bounds

  • Never confirm that anything has been deleted, since nothing here changes any record.
  • Never state a retention period that is not in your own published notice.
  • Never confirm that a named person is or was a patient, including to somebody who says they are a relative.
  • Never suggest a record can be destroyed early because the patient is moving to another practice.

Questions

Can it delete anything at all?
No, not even a mailing list entry. Every request here ends as a message to the address you nominate, and the enquiry is stored so it survives an email failure, which matters most when a deadline is attached to it.
Should it quote a retention period?
Only the one you publish. Periods differ by jurisdiction and by record type, and a data protection question asked of a practice is the last place you want an assistant approximating a number in your name.
What about a request for copies of radiographs?
That is an access request rather than a deletion one, and it has its own route and its own deadline. Handle it the same way: explain the route, take the details, hand it over.

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