Equity and Inclusion Data Strategy

CDTO collects demographic and identity-based data to:

– understand the composition of the applicant and registrant populations;
– assess representation across the profession;
– identify potential differences in access, experiences and regulatory outcomes;
-identify and remove systemic barriers;
– support fair and inclusive policies and programs;
– evaluate the effect of equity-related initiatives;
– inform outreach and engagement activities; and
– measure progress over time. 

CDTO’s existing strategy page identifies representation, inequities, targeted action and measurement of progress as the principal purposes of collection. 

This section should clearly distinguish between:
1. information currently collected and reported;
2. information currently collected but not yet publicly reported; and
3. information CDTO may consider collecting in the future. 

That distinction is important because the existing webpage lists gender identity, Indigenous identity, racialized group, sexual orientation, disability and newcomer status, while the annual and OFC reports do not necessarily publish results for every listed category. 

Registration applications 

Annual renewal 

Additional or future voluntary information 

This could include: 

• Indigenous identity; 

• disability status; 

• sexual orientation; 

• newcomer status; 

• length of time in Canada; 

• other identity categories approved through consultation and policy review. 

CDTO may invite individuals to provide demographic information at the following points: 

New registration 

Applicants may be invited to provide voluntary demographic information as part of the online registration application. 

Annual renewal 

Existing registrants may review or update their voluntary demographic information during annual renewal. 

Voluntary surveys 

CDTO may occasionally conduct surveys to better understand the experiences of applicants, registrants, Board and committee members, or members of the public. 

The existing strategy page identifies new registration, annual renewal and voluntary annual surveys as its collection channels. 

Before asking an identity-based question, CDTO will explain: 

• why the information is being requested; 

• whether answering is voluntary; 

• how the information will be used; 

• who will have access to it; 

• how results will be reported; 

• whether the response can be changed later; and 

• how to contact CDTO with a privacy or data question. 

Applicants and registrants should always have the option to select: 

Prefer not to answer 

How the information may be used 

• Analyze representation within the profession 

• Review registration pathways and outcomes 

• Identify possible systemic barriers 

• Conduct equity impact assessments 

• Improve policies, programs and communications 

• Inform outreach and engagement 

• Measure changes over multiple reporting periods 

• Support aggregate regulatory and health-workforce planning 

How the information will not be used 

Subject to confirmation through CDTO’s approved policies, the page should state that demographic responses will not be used to: 

• determine an applicant’s eligibility for registration; 

• assess an individual’s professional competence; 

• make complaints, discipline or quality-assurance decisions about an individual; 

• market products or services; 

• publish identifiable individual information; or 

• create profiles of individual applicants or registrants. 

Collection authority and purpose 

Identify the specific legal, regulatory or policy authority relied upon by CDTO and clearly state the purpose of collection. 

Access controls 

Explain which roles may access identifiable information and which staff receive only anonymized or aggregate datasets. 

Separation from regulatory decision-making 

Explain whether demographic information is stored separately from application assessment, complaints, discipline and quality-assurance records. 

Data security 

Describe, at a high level: 

• technical safeguards; 

• administrative safeguards; 

• staff confidentiality obligations; 

• access monitoring; and 

• incident-response procedures. 

Retention and deletion 

State: 

• how long identifiable demographic information is retained; 

• when information is anonymized; 

• when it is securely destroyed; and 

• whether registrants may request a correction. 

Small-number suppression 

Explain that results involving very small groups may be combined or suppressed to reduce the risk of identifying individuals. 

Data sharing 

Identify whether aggregate or record-level information may be shared with: 

• the Ministry of Health; 

• the Office of the Fairness Commissioner; 

• research or evaluation partners; 

• other health regulators; or 

• service providers operating CDTO’s database. 

1. Why is CDTO asking me these questions?
   CDTO is asking voluntary demographic and identity-based questions to better understand the people applying to and registered in the dental technology profession in Ontario. This information helps CDTO assess representation, identify possible systemic barriers, guide targeted action and measure progress toward equity and inclusion goals. CDTO’s Equity and Inclusion Data Strategy states that demographic data supports fairer policies, more inclusive practices and a more representative regulatory environment.
2. Do I have to answer?
   No. Demographic and identity-based questions are voluntary. You may choose not to answer any voluntary question, and you may select “Prefer not to answer” where that option is available. CDTO’s current Data Strategy states that data is collected voluntarily and confidentially and that registrants may choose “Prefer not to answer.” 
3. Will my answers affect my application?
   No. Your voluntary demographic answers will not be used to decide whether you meet the requirements for registration. Registration decisions are based on the registration requirements that apply to the profession, such as education, competency assessment, professional liability insurance, good character declarations and other requirements described in CDTO’s Fair Registration Practices Report.
4. Will my answers affect my registration? No. Your voluntary demographic answers will not affect your registration status, your ability to renew, or your standing with CDTO. The information is collected to support aggregate analysis, equity review, outreach, policy improvement and inclusive regulatory planning, not to make individual decisions about a registrant. 
5. Can Registration Committee members see my answers?No, voluntary demographic information should not be provided to Registration Committee members for the purpose of deciding an individual application. Registration Committee decisions should be based on whether an applicant meets CDTO’s registration requirements. Demographic information is collected for equity analysis and reporting at an aggregate level, not for individual registration decision-making.
6. Will the information appear on the public register? No. Individual demographic or identity-based responses will not appear on CDTO’s public register. CDTO’s public register is used to provide information about current and former registrants, and CDTO’s by-laws set out what information may appear on the public register. Demographic data collected through the Data Strategy should be reported only in anonymized and aggregated form. 
7. Who can access identifiable demographic data? Access to identifiable demographic data will be limited to authorized CDTO staff or service providers who require access for an approved purpose, such as secure collection, data management, analysis or reporting. Public reporting will use anonymized and aggregated information. CDTO’s website privacy terms state that CDTO takes appropriate security measures to protect information entered on secure pages or online forms. 
8. Can I change or remove my answers? 
   

   Yes. Applicants and registrants should be able to update or change their voluntary demographic responses through the process established by CDTO, such as during annual renewal or by contacting the College. Registrants may also choose “Prefer not to answer” for voluntary questions.

9. How does CDTO protect small groups from being identified? 
   CDTO reports demographic findings in anonymized and aggregated form. Where numbers are very small, CDTO may combine categories, suppress results or delay reporting to reduce the risk that an individual could be identified. Ontario’s Anti-Racism Data Standards emphasize de-identification for public release and reporting, while preserving useful information where possible.

10. Does CDTO share the information with the Ministry? CDTO collects health human resource information during annual renewal, including demographic and practice-related information, to support planning and statistical analysis. CDTO’s Accountability Reports page states that this information is used by the Ministry of Health for health human resource planning. Any sharing of demographic or identity-based information should be done only as authorized, required and appropriate, and should use aggregate or de-identified information wherever possible. 
11. Why does CDTO collect race-based data? 
    

    Race-based data can help identify patterns that may not be visible through general data alone. It can support CDTO in assessing whether racialized groups experience barriers in registration or other regulatory processes, and can inform outreach, policy review and process improvements. CDTO’s 2025 Fair Registration Practices Report states that race-based data is intended to help identify whether certain groups experience barriers and, over time, inform equity reviews, policy and process improvements and decision-making.

    The Ontario Human Rights Commission also recognizes that collecting and analyzing race-based and other human-rights-based data can be appropriate when used to monitor discrimination, identify and remove systemic barriers, address historical disadvantage and promote substantive equality.

12. How will CDTO act on the results?CDTO will review the results to identify possible gaps, trends or barriers. The information may be used to support outreach, equity reviews, policy and process improvements, inclusive communications, education and other targeted actions. CDTO’s 2025 Fair Registration Practices Report states that anonymized data from renewals, new registrations and voluntary surveys will inform equity reviews, policy and process improvements and decision-making to promote a fair, accessible and inclusive profession.
13. How often will the results be updated?CDTO should update demographic and race-based results at least annually, once each reporting cycle is complete and the data has been reviewed. CDTO’s Data Strategy states that findings will be shared through annual reports, a dedicated Data Strategy webpage and presentations to system partners and the profession. CDTO’s Accountability Reports page also explains that annual reports and Fair Registration Practices Reports are posted publicly each year.
14. Who can I contact with a privacy concern?
    Questions or concerns about CDTO’s Equity and Inclusion Data Strategy, privacy or demographic information may be directed to CDTO.