Luna,
the AI agent for dentists and clinics.

Appointments

Reminders

Phone

Texts

Which law applies

the LRSSS (Act respecting health and social services information, Loi sur les renseignements de santé et de services sociaux), not just Quebec's Law 25: Schedule II of the LRSSS lists among health sector bodies any person who operates a private professional practice, which covers a clinic where dentists practise on their own account. The private-sector privacy act (Quebec's Law 25) does not apply to this health information (art. 3, par. 3°). A patient's name or contact details are part of it when attached to health information or collected for their care (LRSSS, art. 2). Have your situation confirmed by your advisor.

A written contract with the agent's provider

A clinic may entrust information to a provider if it is necessary for the contract, but the contract must be in writing and contain, on pain of nullity, the clauses of art. 77 of the LRSSS: confidentiality measures, a commitment signed by each person with access, notice of any breach, destruction at the end of the contract, and subcontractors bound by the same obligations. The information is still considered held by the clinic even if it is kept with a third party (art. 5). Before signing, ask us in writing how we meet each of these clauses.

Ask only for what the appointment needs

A body may collect only the information necessary for its activities (art. 13) and must inform the person, in plain terms, of who is collecting and for what purposes (art. 14). Luna asks the questions on your intake form, nothing more, and its welcome message is written with you.

Entering the agent in the register of technology products

The LRSSS requires every technology product or service used to be entered in a register, and that register to be published on the clinic's website (art. 107). Luna appears there like any intake or appointment-booking tool.

Professional secrecy

the dentist is also answerable for their tools: The dentist must respect the secrecy of all confidential information (art. 3.06.01) and take reasonable measures with regard to the people who work with them to preserve it (art. 3.06.03, 3°). In practice: no clinical details in text messages, access to conversations limited to the people you designate, and all conversations available for review. The Professional Code (Code des professions) sets the same rule for every professional (art. 60.4).

Fees and advertising

Providing the explanations needed to understand fees is the dentist's responsibility (art. 3.08.03): Luna answers only from the information you give it and hands off for a treatment plan. The dentist may not use testimonials of support in advertising (art. 3.09.10): the posts Luna prepares contain none, and nothing is published without your approval.

Cleaning reminders by text message or email

Under Canada's Anti-Spam Legislation (Loi canadienne anti-pourriel, CASL/LCAP), a patient who bought a service from the clinic in the last two years has an existing business relationship with it (art. 10(10)a)): this is implied consent to remind them that a cleaning is due. Each commercial message identifies the clinic and offers a way to unsubscribe (art. 6(2)).