
As a Dentist, you are well accustomed to challenging situations, but the thought of going through the disciplinary process of the College of Dental Surgeons of Alberta (the “CDSA” or the “College”) might still intimidate you. It is completely normal for someone to be filled with questions and anxiety when under regulatory scrutiny, after all, their career, finances, and reputation are on the line.
This article presents some essential information you should know if you are facing or expecting a CDSA regulatory action.
This article should, however, be treated as for informational purposes only. The CDSA has legally binding licensing and regulatory powers; its discipline can have severe financial, career and reputational consequences. The procedures involved are highly complex, intense and disruptive; and throughout the process, your rights to fairness are engaged. Hence, it is highly recommended that you retain legal counsel to leverage their legal expertise and practical experience to strategically defend your case and minimize stress, instead of risking it alone.
Taylor Janis offers legal services to all professionals facing regulatory actions across Alberta. Contact us at our Edmonton or Calgary office today to schedule an initial consultation.
The CDSA has Statutory Disciplinary Powers
The Regulated Members of the CDSA
Under the Alberta Health Professions Act (the “Act”) and its accompanying Dentists Profession Regulation, the College of Dental Surgeons of Alberta is the regulatory college that regulates the profession of dentistry, and its regulated members include:
- Dentists and dental surgeons practicing in Alberta;
- Dentistry instructors, clinical researchers and graduate students registered with the CDSA;
- Out-of-province dentists temporarily attending or providing hands-on courses in Alberta.
Therefore, if you are under one of the three categories above, you are subject to the CDSA’s statutory regulatory powers.
Other professionals working in the provision of dental or oral health care, such as dental assistants, dental hygienists, dental technologists, and denturists, are NOT regulated by the CDSA under the Act, but by their respective regulatory bodies. The regulatory framework governing these professions shares some similarities with the one governing dentists. If you belong to any of these professions and are facing regulatory scrutiny, you can also contact Taylor Janis for legal advice.
The CDSA’s Disciplinary Measures
Dentists in Alberta have the privilege to self-regulate under the Act, and this privilege is expressed partly through the CDSA’s broad powers and discretion in making disciplinary decisions with direct or indirect legally binding effects on its regulated members. The CDSA Hearing Tribunal may order one or more of the following against a regulated member who has been found to have committed unprofessional conduct:
- A caution or reprimand;
- Imposition of conditions and/or restrictions on their practice permit;
- Suspension of their practice permit temporarily or until certain conditions are satisfied;
- Requiring them to satisfy competence requirements;
- They may be required to receive counselling or treatment programs, complete specific courses of study, or obtain supervised practical experience within a fixed period, during which the practice permit may be suspended.
- Cancellation of their registration and practice permit;
- Repayment of improper fees received from the complainant;
- Recovery of certain expenses incurred during the disciplinary process from the regulated member;
- A fine not exceeding $10,000 for each finding of unprofessional conduct and not exceeding $50,000 for the aggregation of all unprofessional conduct found at one hearing; and
- Any other order deemed appropriate for the protection of the public.
It is important to bear in mind that the list above is somewhat open-ended. As a regulatory college, the CDSA has some discretion to appropriately “tailor” somewhat novel disciplinary measures to protect the public. It can also remain “seized” with a disciplinary matter, meaning it may order further discipline or apply for court interventions if an initial order was not complied with. Moreover, the CDSA must forward its written disciplinary decision to the Minister of Justice if its Hearing Tribunal finds probable and reasonable grounds to believe the matter raises criminal concerns. Thus, non-compliance with disciplinary orders or egregious conduct may result in further legal liabilities.
The Damaging Effects of Discipline
An adverse disciplinary decision by the CDSA can be profoundly disruptive and damaging to a disciplined dentist’s career, finances, and reputation. This is true even for a seemingly “lesser” discipline.
A fine or suspension of practice permit is obviously a direct career and financial setback, but one also has to take into account the potential disruption a disciplinary measure can bring to their practice. For example, a dentist’s practice can be severely disrupted when an onerous restriction or condition is placed upon their practice permit, such as receiving additional training or supervision until the CDSA is eventually satisfied that a regulated member is competent to provide dental care, as their attention will inevitably be diverted from providing dental care services.
Moreover, long-lasting and irreversible reputational harm may occur. Under the Act and the CDSA Bylaws, summaries of written hearing decisions regarding substantiated findings of unprofessional conduct must be published on the CDSA’s newsletter and website, and they will remain accessible on the website for 5 years. Moreover, information regarding cancellation or suspension of, or conditions placed on practice permits, will be shared with the impugned dentist’s employer and regulatory bodies for dentists in other provinces, resulting in severe and irreversible reputational harm that may affect a dentist’s ability to practice in other provinces.
It is also important to bear in mind that the reputational harm may emerge even before a final decision is eventually made, as the disciplinary process is substantially transparent to the public, which will be discussed in the next section of this article.
Legal Representation
If you are facing CDSA’s regulatory scrutiny, you should be aware of the legally binding effects and the potential of severe financial, career and reputational consequences. You should also consider retaining legal counsel to assess and mitigate the potential risks.
The CDSA Disciplinary Process
The disciplinary process of the CDSA is complex and largely transparent to the public. This is because procedural fairness and transparency are essential to making fair disciplinary decisions, as well as to protecting the interests of both the public and the dental profession.
The procedures involved in a disciplinary process can often be intense, stressful and disruptive to a dentist’s practice. To help you stay informed, we have compiled some information about the major procedures.
The CDSA disciplinary process involves a sequence of escalating procedures. However, legal advice should not be left to the last minute, as even the early stages can be highly stressful, complex, consequential and disruptive. Our strongest recommendation is that you obtain legal counsel at an early stage and have them engaged throughout the entire process, so you stay well-informed and prepared when navigating the procedural complexities.
The Complaint Process
Any person can file a complaint with the CDSA Complaints Director against a regulated member. Therefore, a complaint does not necessarily arise out of a dentist-patient relationship. The CDSA received 176 complaints during their 2024 fiscal year, and during the same period, it had 3,194 regulated members in total. Given the high expectations the public places on dentists and the sensitive nature of the dentist-patient relationship, it is possible for a dentist committed to high ethical and professionalism standards to have a complaint against them.
Moreover, under certain circumstances, an employer or fellow dentists of a regulated member of the CDSA must report to the College their concerns regarding that regulated member’s unprofessional conduct. If the Complaints Director has reasonable grounds (can be based on information received internally or externally ) to believe a regulated member has committed unprofessional conduct, they can act on it as if a complaint has been received. Hence, a disciplinary process may ensue without a complaint.
The CDSA Complaint Director may only dismiss a complaint if they have determined that the complaint is trivial or vexatious, or lacks factual or legal merit. Otherwise, the options available to the Complaint Director are to either attempt to facilitate voluntary or alternative resolution or to initiate an investigation.
The Investigation
If a complaint is not summarily dismissed or resolved through a voluntary or alternative resolution process, an investigation will commence, and the investigated person will normally be notified of the particulars of the allegation against them.
The CDSA has a broad range of investigatory powers, to which an investigated person must comply. An investigator may do one or more of the following:
- Require an investigated person to answer questions under oath, and/or to disclose information and/or evidence relevant to the investigation;
- They may also apply to the Court of King’s Bench for a court order to enforce such requirements;
- Have the investigator enter and inspect the investigated person’s premises for dental practice, subject to a few limitations under the Act; and
- Temporarily suspend, or place conditions on, an investigated person’s practice permit.
An investigation can be highly disruptive to your dental practice, and legal advice is highly recommended to help you avoid inadvertently jeopardizing your own case while cooperating with the investigation.
When an investigation is eventually completed, unless the complaint is dismissed for being trivial, vexatious or factually meritless, the investigated matter will be referred to the CDSA Hearing Tribunal.
The Hearing
A hearing by the CDSA Hearing Tribunal is for the purpose of determining the factual veracity of the alleged unprofessional conduct and appropriate disciplinary orders. Its procedure is intense and considered quasi-judicial, where often extensive preparation is required to successfully defend against a complaint. Below are a few things you should know if you are expecting a hearing:
- The timeline for preparation is intense: A hearing would normally be scheduled within 90 days after a complaint has been referred to the CDSA Hearings Director, but the notice to an investigated person can be as short as 30 days.
- A hearing may have profound reputational consequences: A hearing is presumed to be open to the public unless there are overriding legal reasons under the Act for it to be held partially or entirely in private. Hence, a dentist’s conduct and preparedness at a hearing can be under public scrutiny.
- The hearing process can be considered quasi-judicial, which means:
- The process is court-like and adversarial. The parties (the College vs. an investigated person) are expected to contend factual and legal positions, and both have statutory rights to counsel.
- The contention is often intense, and a decision is made based on the relative strength of the parties’ submissions. Hence, extensive preparation with legal advice is highly recommended.
- An investigated person may be compelled (i.e. legally bound) to testify as a witness and be examined (i.e. scrutinized by questions) under oath.
Once a complaint reaches the hearing stage, the stress and risks are often significantly elevated. If you are expecting to go through a hearing, you should exercise your statutory right to counsel.
Appeal
An investigated person may appeal a hearing decision internally to the CDSA Council within 30 days of receiving the decision, and they can further appeal the CDSA Council’s decision to the Alberta Court of Appeal for judicial remedies within 30 days of receiving it.
However, appeals should be seen as a last resort after the fact of an adverse decision, and it is far more preferable to receive a favourable decision at an early stage. There are a few reasons for this:
- Once it has been made, it becomes a monumental task to have a decision overturned, as the appellate standards are high and courts are required to pay deferential respect to statutory regulators following the Vavilov decision of the Supreme Court of Canada.
- An appeal can normally concern only issues related to bias, and procedural or substantive fairness of the impugned decision. Hence, generally, the parties are not allowed to submit additional evidence to defend against the alleged professional misconduct, and successful appeals are only feasible with strong legal arguments applied to records of materially unfair decisions.
- Neither an internal appeal nor an appeal to the court would automatically halt the enforcement of the order made by the Hearing Tribunal. Moreover, even if an appeal is successful, the remedy might be that the matter is sent back to be redecided. Hence, whilst you are dealing with the complex appeal procedures, the damages of an adverse decision will most likely irreversibly manifest in the background.
Hence, if it becomes necessary to appeal a decision, the value of legal representation is eminently clear. However, the most preferable approach is to engage early legal representation and have a sound defence at the early stages to maximize the chance of a favourable initial decision.
Voluntary/ Alternative Resolutions
Alternative to going through the entire hearing process, an investigated person can resolve a complaint through voluntary processes, including:
- Voluntary settlement: At any time before a complaint is referred to the Hearing Tribunal, the investigated person can voluntarily communicate with the complainant to resolve the complaint through a voluntary settlement, and the CDSA has discretion to recommend and mediate a voluntary alternative complaint resolution process.
- Admission of unprofessional conduct: the investigated person can also admit to unprofessional conduct at any time before the decision has been made by the Hearing Tribunal. The Hearing Tribunal then has a discretion as to whether to accept the admission and make appropriate disciplinary orders.
However, these options should not be exercised hastily without obtaining legal advice first, and there are a few reasons for this:
- Settlement agreements are legally enforceable under most circumstances. Hence, when proposing a settlement, you need to consider all factual and legal factors and make sure the terms are not unduly onerous or prejudicial to you.
- An admission of unprofessional conduct does not equate to lesser consequences. Remember, an admission only substitutes the fact-finding process of a hearing process, and the Hearing Tribunal will make disciplinary orders according to the admitted facts. Moreover, the decision will be polished like any other Hearing Tribunal decision.
- Also, the admission of unprofessional conduct will substantially foreclose any possibility of appealing a decision for unreasonable factual findings.
The Importance of Early Legal Representation
Going through a CDSA disciplinary process alone can be a daunting task with high consequences, and the stress keeps heightening as the procedures escalate. The CDSA’s investigatory powers can be highly disruptive to your dental practice. Under certain circumstances, a suspension, condition or restriction may be imposed on your practice permit. Moreover, the procedures can have profound reputational implications even before a final decision is made.
Throughout all stages of a disciplinary process, you need to respond in a legally informed manner and avoid inadvertently jeopardizing your case. When presented with an opportunity for a voluntary resolution, you need to make strategically sound decisions, taking into account all relevant legal and factual factors.
A lawyer can help you navigate the complex procedures and streamline the process where possible, thus mitigating the stress and disruptive effects. They will also help you stay informed when cooperating with the CDSA or making key decisions, thus avoiding legal pitfalls.
If you need a skilled lawyer who is experienced with regulatory actions and disciplinary processes, please contact Taylor Janis and discuss your situation, even if you are at an early or preliminary stage of the disciplinary process, as early legal representation can be key in achieving early favourable resolutions.
*The procedures cited above may vary if the alleged unprofessional conduct is related to the incapacity of the regulated member, sexual misconduct, or the procurement or performance of female genital mutilation.
Your Rights When Undergoing Disciplinary Procedures
An investigated person’s administrative law and common law rights are engaged every step of the way throughout a CDSA disciplinary process, and some of these rights even have constitutional gravity. Sometimes, an individual’s rights can affect or even determine the outcome, so you should be aware of such rights and be ready to vigilantly protect them, ideally by having legal counsel engaged with the entire process.
Understanding the Rights
The rights a person has when undergoing regulatory actions are ultimately informed by the principles of natural justice and fairness, which can be a difficult and abstract legal concept to grasp. It is often equally difficult to apply it to the circumstances and discern whether a right is indeed infringed upon, especially without legal guidance.
However, to summarize it for informational purposes, your rights can be broken down into three broad but distinct categories:
- Right to procedural fairness:
- At its core, this means everyone is entitled to know the particulars of the allegation against them and have appropriate opportunities to answer and make a full defence.
- The procedures and organizational practices designed to protect this right are found in the Act, its accompanying regulations, and the CDSA Bylaws. However, the CDSA does retain a slight discretion to select and conduct the procedures as they deem appropriate under certain circumstances.
- Inappropriate procedures or appropriate procedures done inappropriately can both infringe the right to procedural fairness. Hence, the ideal way to safeguard procedural fairness is to flag and object to infringements as they arise during the process, whereas attempting to address unfair procedures after the fact through an appeal is subject to stringent legal and evidentiary standards.
- Right to substantive fairness:
- This means a decision and its reasoning must meet certain standards.
- The Act provides that a final disciplinary decision made by the CDSA Council can be appealed to the Alberta Court of Appeal. Hence, pursuant to Vavilov, the applicable standards here are “no palpable and overriding errors” in factual findings and “correctness” in the application of laws.
- The applicable standards here are the same as the appellate standards used on appeals from lower courts, and they are subject to stringent legal and evidentiary tests. Also, appellate courts are, at common law, required to be deferential to regulatory decision makers. Hence, the ideal way to safeguard this right is to have legal counsel advocate for legally correct and factually reasonable decisions.
- Right to unbiased decision makers:
- This requires the decision makers not to give a reasonable apprehension of bias to a reasonable bystander observing the entire decision-making process.
- Reasonable apprehension of bias is a high legal and factual threshold; it is not any apprehension of bias. Hence, if a biased decision has been made, it is difficult to correct the wrongs through appellate actions. Again, this right is best protected by flagging and objecting to biases as they become evident.
Safeguarding Rights Through Early and Ongoing Legal Representation
Your rights are embedded in and affected by every procedure of a CDSA disciplinary process. Ideally, infringements should be addressed as soon as they emerge. This is because it is a mounting challenge to appeal an unfair decision after it has been made.
Hence, it is strongly recommended that you retain legal counsel early and have them engaged with the entire process, upholding your rights at every stage.
Taylor Janis is dedicated to upholding our clients’ rights. Contact us today to schedule an initial consultation and secure skilled legal representation.
Strategic Defence against A Complaint
Defending against a complaint is not just about telling your perspective of what happened. An effective defence often requires correctly applying legal rules to facts substantiated with strong evidence, with skillful advocacy enhancing its persuasiveness. This can be especially true if the factual and legal issues involved in a complaint are contentious.
Know the Applicable Rules:
Under the Act, unprofessional conduct is disciplinable and actually captures a wide range of conduct:
- Displaying a lack of knowledge, skill or judgment when practicing dentistry;
- Contravention of applicable legislation, code of ethics or standards of practice;
- Practicing dentistry without an appropriate practice permit or registration, or in ways contravening the conditions imposed on a practice permit;
- Non-compliance with an investigatory request or disciplinary decision of the CDSA; and
- Conduct that harms the integrity of the profession of dentists.
However, the above is not an exhaustive list of all the conduct that may attract discipline, nor does it lead to a comprehensive understanding of how disciplinary decisions are made. The rules are multi-layered and often nuanced, and a CDSA disciplinary decision may be informed by statutes and case laws other than the ones specifically governing its regulated members. When preparing a strategic legal defence, it is important to know:
- There are multiple sources of rules specifically applicable to regulated members of the CDSA:
- Any contravention of the CDSA Bylaws, the CDSA Code of Ethics, or the CDSA Standards of Practice can be considered unprofessional conduct under the Act.
- The rules found in these sources range from detailed technical guidelines and administrative guidelines to broad overarching ethical and professional duties. It may prove challenging to keep track of all these “boundary” rules while staying committed to your practice, and you should leverage your legal counsel’s legal knowledge and research skills to interpret and cite rules when formulating a legal defence.
- Legal rules are nuanced, especially when they interact with each other:
- A regulated member of the CDSA, like everyone else, has an overarching duty to act pursuant to the law at large, and correspondingly, the CDSA should make disciplinary decisions within the framework of jurisprudence and established legal principles.
- Your lawyer can strategically defend your case by citing applicable governing legal authorities. For example, a dentist has a duty to keep the confidentiality of patient information; however, there are statutory and common law exceptions to this rule, where the correct application of such rules can be a basis of strong legal arguments.
Hence, legal counsel often plays an indispensable part in formulating robust legal defences by leveraging their legal expertise to resourcefully reference and apply a wide range of legal authorities.
Substantiate Facts with Admissible Evidence
Other than the law, the facts are also often intensely disputed during CDSA disciplinary proceedings. Ultimately, a fair decision can only be made on the relative strength of competing evidence from both parties.
Legal representation can be critical to building a robust factual defence, because:
- The probative value, factual materiality and legal relevance of evidence may not be obvious without proper organization and presentation, and a lawyer as an advocate can highlight the legal and factual nexus of key pieces of evidence as well as highlight evidentiary features that might be otherwise underconsidered.
- The CDSA Hearing Tribunal is not strictly bound by the courts’ rules of evidence, yet its factual findings must not contain palpable and overriding errors. A lawyer can identify problematic evidence and highlight issues such as irrelevance, unreliability or undue prejudice; this can be crucial in preventing unfair or unreasonable verdicts.
Highlight Key Issues through Advocacy:
A lawyer, as your advocate, pays undivided loyalty to you and will tenaciously examine the strengths and flaws of each argument. This can be vital to the persuasiveness of your defence.
Your legal advocate also assists the adjudicator in making a fair decision, for example:
- A skillful advocate can highlight hidden but important factors which may otherwise be overlooked.
- This can be especially instrumental when complex or principled analysis is engaged.
- For example, the CDSA Code of Ethics requires a dentist to “do good” and “be competent”. Dentists regularly exercise professional judgment when treating a patient. Whether a particular decision is competent and appropriate is a question best approached with a thorough analysis of all relevant factors, many of which may not be obvious.
- A resourceful advocate can assist the decision-makers with issues that are not within their expertise.
- Members of the Hearing Tribunal may not necessarily possess the same level of judicial training as a judge. When a legal rule or principle is at issue, legal counsel can play a crucial role in supporting their efforts to make fair decisions.
- Moreover, as discussed in the previous section of this article, tenacious advocacy may be necessary to protect your administrative law rights when undergoing a regulatory action.
Choose a Tailored Legal Plan
Engage Legal Representation Early Rather than Late
CDSA disciplinary decisions can have legally binding financial, career and reputational consequences on its regulated members. The disciplinary process is a ladder of escalation, with each stage heightening the intensity, consequentialness, and potential for secondary reputational harm, and throughout the process, your rights are always engaged and require vigilant safeguarding. To successfully defend against a complaint is a matter of strategic planning, advocacy, as well as strong legal and factual arguments. Moreover, once it has been made, it is a monumental challenge to have an adverse decision overturned.
Hence, if you are under the CDSA’s disciplinary scrutiny, we strongly recommend that you engage legal representation early rather than late, as early involvement of skilled legal counsel can be instrumental in safeguarding your rights, navigating and streamlining the procedures, and formulating a robust defence strategy.
Start with An Initial Consultation
Taylor Janis appreciates that every case is different, and so are the needs of each client. Hence, we always tailor our legal plans on a case-by-case and client-by-client basis.
Whether you are looking for legal expertise, tenacious advocacy or resourceful problem solving, you can contact Taylor Janis Workplace Law at our Edmonton or Calgary office today to schedule an initial consultation to discuss your case. We provide services to all professionals facing regulatory actions within all areas of Alberta.
Frequently Asked Questions
How Long Do CDSA Complaints Typically Take to Resolve?
This would vary greatly depending on various factors, including the nature of the claim and whether an alternative resolution is entered by the parties. A meritless complaint can be dismissed fairly quickly, but if a complaint results in an investigation or hearing, then the process can take a few months to upwards of a year. Alternative dispute resolution (i.e. settlement or admission to unprofessional conduct) may shorten the timeline significantly, but such options should not be exercised hastily without carefully and strategically assessing the entire circumstances first. If you are concerned about the disruptive effects, you should consider obtaining legal advice and exploring opportunities for streamlining the process.
I Disagree with a CDSA Disciplinary Decision against Me. What Should I Do Now?
You may consider appealing the decision to the CDSA council, and if this is not successful, you may appeal the council’s decision to the Court of King’s Bench. However, in deciding to do these, you should be aware of a few things. First, an appeal is based on the decision and its records and generally, only questions related to fairness will be heard; in other words, an appeal is not a redetermination of whether the alleged unprofessional conduct indeed occurred. Second, the time limit for initiating an appeal is short, which is within 30 days of receiving a decision. Third, if the original decision is affecting your practice, you should apply to the council or the court for a stay of the order, and this application is a challenging task in itself. Hence, if you are weighing whether to appeal a decision, the strongest recommendation is that you talk to a lawyer first.
My Patient Has Signed a Waiver before Receiving Treatment. Does this Mean I am Shielded from a Complaint?
A dental treatment liability waiver can only waive a patient’s ability to make certain claims, such as for damages that occurred because of the expected risks inherent in dental treatments competently performed according to applicable standards. A waiver cannot completely waive an oral health professional’s legal obligations, nor can it waive potential claims such as gross negligence, and any terms attempting to do so would be legally unenforceable. Hence, a liability waiver will not necessarily shield you from complaints, and the ideal way to assess risk is to have a lawyer review the waiver as well as the claim.
Should I Consult a Lawyer if the Complaint Against Me Is Trivial / Unfounded?
We recommend seeking legal advice even if a complaint is seemingly trivial, frivolous, vexatious or unfounded. Here are a few reasons for this. First, the rules are complex and may pertain to seemingly trivial things, and although you may disagree with the perspective of the complainant, they may nonetheless have some circumstantial evidence to support a complaint. It is difficult to fully assess the potential risks without an in-depth analysis of the complaint and applicable rules. Second, having legal representation shows that you are taking the situation seriously and are prepared to act accordingly; this could be an advantage as it may discourage frivolous or vexatious complaints from being further processed. Third and finally, if the complaint truly poses no risk, at least you get the peace of mind to stay focused on your practice after a quick consultation with a lawyer.
Can a CDSA Complaint Lead to Further Legal Proceedings and Liabilities?
It depends. The alternative complaint resolution process between a regulated member and a complainant is bound by voluntary confidentiality. Hence, any record of this process (apart from a ratified settlement agreement or expert report prepared for this process) cannot be used in future legal proceedings without the parties’ consent, except that information relevant to sexual misconduct or the performance or procurement of female genital mutilation will be forwarded to law enforcement. This confidentiality could prove to be advantageous, but you should obtain legal advice for a fair and reasonable settlement.
Other proceedings are not confidential. Records arising from each proceeding may be used in a future one if they are otherwise admissible under relevant evidence rules. Moreover, the CDSA must forward relevant information obtained through a hearing to the Minister of Justice if there are reasonable and probable grounds to believe the regulated member has committed a crime. Hence, you should be extra cautious with your conduct during a proceeding, ideally with legal representation.
Conclusion
A CDSA disciplinary action can have severe and legally binding consequences, affecting your finances, career and reputation. The disciplinary procedures can be intensely disruptive and complex to navigate, throughout which your legal rights are engaged, and strategically defending a case often requires legal expertise and skillful advocacy. Please do not hesitate to contact us today, whether you are undergoing a disciplinary process or are expecting one. Taylor Janis Workplace Law looks forward to helping you through this testing time. Contact our Edmonton and Caltgary office to schedule a consultation.
References:
- Health Professions Act, RSA 2000, c H-7
- Dentists Profession Regulation, Alta Reg 254/2001
- College of Dental Surgeons of Alberta Bylaws (October 2024)
- CDSA Code of Ethics (November 2023)
- Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65 (CanLII), [2019] 4 SCR 653
- 2024 Annual Report, CDSA
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