Responsibilities of a Dental Specialty Clinic in Cases of Personal Data Disclosure

A Dental Specialty Clinic is a healthcare facility responsible for storing and processing patients’ sensitive personal information. The disclosure of personal data at a Dental Specialty Clinic not only constitutes a legal violation but can also result in serious consequences. So, what are the responsibilities of a Dental Specialty Clinic when the personal data of data subjects is disclosed under the latest regulations?

This article by VDPC will analyze the specific legal obligations related to sensitive personal data that Dental Specialty Clinics must comply with, while also clarifying the applicable administrative penalties in accordance with the law

Legal basis:

• Article 3, 7, 8, 37 Law on Personal Data Protection 2025
• Article 46 Decree No. 98/2020/ND-CP as amended and supplemented by  Decree No. 24/2025/NĐ-CP
• Article 4, 38 Decree No. 117/2020/ND-CP

1. Responsibilities of a Dental Specialty Clinic

A Dental Specialty Clinic may act as a Personal Data Controlling Party (an agency, organization, or individual that determines the purposes and means of personal data processing) or as a Personal Data Controlling and Processing Party (an agency, organization, or individual that determines the purposes, means, and directly processes personal data). Accordingly, the clinic may have the following responsibilities:

(1) The Personal Data Controlling party bears the following responsibilities:

• Specify the responsibilities, rights, and obligations of the concerned parties to be complied with in agreements or contracts regarding personal data processing, pursuant to regulations
• Decide on the purposes and means of personal data processing in documents and agreements with personal data subject matters, ensuring compliance with the principles and contents 
• Adopt appropriate managerial and technical measures to protect personal data according to the law and review and update such measures if necessary
• Issue notices of violations against personal data protection regulations 
• Select an appropriate personal data processing party to process personal data
• Ensure the rights of personal data subject matters
• Assume responsibility before personal data subject matters for any damage arising from personal data processing
• Prevent unauthorized collection of personal data from its system, equipment, and service
• Cooperate with the Ministry of Public Security of Vietnam and competent state authorities in protecting personal data, providing information serving the investigation, and handling violations against personal data protection laws
• Implement other responsibilities pursuant to regulations.

(2)  The Personal Data Controlling and Processing party bears the following responsibilities:

• Specify the responsibilities, rights, and obligations of the concerned parties to be complied with in agreements or contracts regarding personal data processing
• Only receive personal data after concluding an agreement or contract on personal data processing with the personal data controlling party or personal data processing and controlling party
• Decide on the purposes and means of personal data processing in documents and agreements with personal data subject matters, ensuring compliance with the principles and contents
• Adopt appropriate managerial and technical measures to protect personal data and review and update such measures if necessary
• Process personal data in compliance with the agreement or contract concluded with the personal data controlling party 
• Issue notices of violations against personal data protection regulations
• Select an appropriate personal data processing party to process personal data

Additionally, there are other responsibilities, such as:

• Ensure the rights of personal data subject matters
• Adequately implement measures to protect personal data pursuant to regulations
• Assume responsibility before personal data subject matters for any damage arising from personal data processing
• Assume responsibility before the personal data controlling party or personal data processing and controlling party for any damage arising from personal data processing
• Prevent unauthorized collection of personal data from its system, equipment, and service
• Cooperate with the Ministry of Public Security of Vietnam and competent state authorities in protecting personal data, providing information serving the investigation, and handling violations against personal data protection laws
• Implement other responsibilities pursuant to regulations.

2. What Responsibilities Does a Dental Specialty Clinic Bear When the Personal Data of Data Subjects Is Disclosed?

Regarding its responsibilities, in the event of a personal data disclosure, a Dental Specialty Clinic may be held liable as follows:

1. Pursuant to the Law on Personal Data Protection, such conduct is strictly prohibited. Organizations or individuals that commit violations may be subject to administrative fines of up to 3 billion VND With respect to civil liability, violators may also be required to compensate for any damages incurred by the personal data subjects, where applicable.
2. Pursuant to Decree No. 98/2020/ND-CP, the act of transferring consumer information to a third party without the consumer’s consent may be subject to fines ranging from 30,000,000 VND to 40,000,000 VND.
3. Pursuant to Decree No. 117/2020/ND-CP, the act of disclosing a patient’s medical condition, information provided by the patient, or hospital medical records at a Dental Specialty Clinic may be subject to fines ranging from  2,000,000 VND to 6,000,000 VND.
4. Additionally, the disclosure of personal data may affect the clinic’s reputation, credibility, revenue, or even its operations if the incident occurs at a serious level.

CONCLUSION

A Dental Specialty Clinic bears a very high legal responsibility in safeguarding sensitive personal data. Ensuring the security of medical information is a critical factor, requiring the clinic to regularly review its security systems and train personnel in accordance with strict legal standards.

The above outlines Responsibilities of a Dental Specialty Clinic in Cases of Personal Data Disclosure. If you have any questions regarding this matter, please contact VDPC for accurate and professional advice.

Sincerely !

Zalo: 098.159.5243

The above is a summary and analysis of legal regulations based on the Advisor’s perspective for reference purposes only. This content does not apply to any specific real-world case, and VDPC shall not be held liable for any application by readers based on the aforementioned information without obtaining professional consultation from experts. Readers are kindly requested to contact us for precise advice tailored to your specific case of interest. Sincerely!

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