Every Ontario dental practice, whatever its size, must have a workplace violence policy and a workplace harassment policy and review both at least once a year. Practices that regularly employ six or more workers must put the policies in writing and post them, and every practice needs a program behind each policy that sets out how incidents are reported, investigated and resolved, including when the alleged harasser is the owner.
Is your practice's harassment policy a document someone wrote years ago and nobody has opened since? For some owners in Toronto and across the GTA, the honest answer may be yes. As of October 2026, the Ontario government's plain-language guide to these rules, Understand the law on workplace violence and harassment, was last updated on 17 August 2026, and it is worth a fresh read. This post walks through what the guide says an Ontario employer must have in place, translated into the realities of a dental practice: a small team, a front desk that deals with upset patients, and an owner who is often also the direct supervisor.
One caution up front, which the guide itself makes: it explains the law but is not legal advice. In the government's words, "If you need help in determining what constitutes compliance, you should consult a lawyer." Treat this as a checklist to bring to that conversation.
What counts as workplace harassment and violence in Ontario?
The definitions are broader than many owners expect. According to the guide, workplace harassment means "engaging in a course of vexatious comment or conduct against a worker in a workplace, including virtually through the use of information and communications technology, that is known or ought reasonably to be known to be unwelcome."
Two parts of that definition matter in a practice. "Virtually" means group chats, texts and email between team members are covered, not just what happens in the operatory or the staff room. "Ought reasonably to be known" means conduct can count as harassment even if the person did not realize it was unwelcome, when they reasonably should have.
The guide lists examples of harassment, including:
- remarks, jokes or innuendos that demean, ridicule, intimidate or offend
- displaying or circulating offensive pictures or materials, in print or electronic form
- bullying
- repeated offensive or intimidating phone calls or emails
- workplace sexual harassment
Workplace sexual harassment has its own definition. It covers a course of vexatious comment or conduct against a worker "because of sex, sexual orientation, gender identity or gender expression" that is known or ought reasonably to be known to be unwelcome, and also an unwelcome sexual solicitation or advance by someone "in a position to confer, grant or deny a benefit or advancement to the worker." In a dental practice, that second branch applies to the people who set schedules, approve raises and decide who gets hired.
Workplace violence is defined as physical force against a worker that "causes or could cause physical injury," and it also includes "a statement or behaviour that a worker could reasonably interpret as a threat to exercise physical force against the worker." A patient at the front desk who threatens to hit a receptionist over a bill falls within that definition even if nobody is touched.
What is not harassment
The guide is equally clear about the other side. "A reasonable action taken by an employer or supervisor relating to the management and direction of workers or the workplace" is not harassment, and "differences of opinion or minor disagreements between co-workers would also not generally be considered workplace harassment." Performance feedback, scheduling and discipline, handled reasonably, are part of running a practice.
Patients count too
The rules are not limited to conflict between staff. The guide says the harassing or violent person may be someone a worker meets because of the nature of the job, and it names "a client, customer, volunteer, student, patient, etc." It also tells employers to address violence "from all possible sources," including strangers and domestic or intimate partners. For a dental practice, the patient population is part of the risk picture.
What policies must an Ontario dental practice have?
The guide states that "every employer in Ontario must prepare and review, at least annually, a policy on workplace violence," and that this applies "regardless of the size of the workplace or the number of workers." The harassment policy carries the same annual review requirement.
The size threshold is about form, not substance. The guide explains that "if six or more workers are regularly employed at a workplace, this policy must be in writing and posted," while below six it "does not necessarily have to be written." Below six, a Ministry of Labour inspector may still order the policy to be in writing. Many multi-chair practices in Mississauga, Vaughan or North York, once hygienists, assistants and front desk staff are counted, may be over that line anyway.
You do not need two separate documents. Asked whether the violence policy can be combined with the harassment policy, the guide answers: "Yes, as long as all the requirements for the policies are complied with."
Pro Tip: The guide does not define "regularly employed," so if part-time staff could bring you to six, write and post the policies anyway; an inspector can order them written in any case. A dated, written policy is also the easiest way to show that a review took place.
What goes into the workplace violence program?
A policy is a statement; a program is how it works in practice. The guide lists what the workplace violence program must include:
- measures and procedures to control the risks identified in the risk assessment
- measures and procedures for summoning immediate assistance
- measures and procedures for workers to report incidents of workplace violence to the employer or supervisor
- how the employer will investigate and deal with incidents or complaints of workplace violence
The risk assessment comes first. The employer "must assess the risk of workplace violence that may arise from the nature of the workplace, type of work or conditions of work," and must repeat it "as often as necessary" so the policy and program keep protecting workers. The guide recommends reviewing the violence program at least annually.
In a dental practice, that assessment usually comes down to a few concrete questions. Who opens and closes alone? Who handles billing disputes at the front desk? Is there an evening or weekend shift with one staff member on? How does someone in an operatory call for help without leaving the patient?
Pro Tip: Write the "summon immediate assistance" step as a specific action that a new hire can follow on day one, such as a named code phrase at the front desk, who responds, and when to call 911. A vague "seek help from a supervisor" fails exactly when the supervisor is the one chairside.
Domestic violence and known risks
Two further duties often surprise owners. First, when an employer is aware, or ought reasonably to be aware, that domestic violence may occur in the workplace and would likely expose a worker to physical injury, the guide says "domestic violence is considered workplace violence," and the employer "must take every precaution reasonable in the circumstances." It adds that "even if a worker does not want any steps taken, the employer may still be required to take some action."
Second, employers and supervisors "must provide workers with information, including personal information, related to a risk of workplace violence from a person with a history of violent behaviour," but "must also not disclose more information than is reasonably necessary" for the worker's protection. For a practice, that can mean telling the front desk and the assigned clinician about a patient with a documented history of aggression, while keeping the rest of that patient's information private.
What goes into the workplace harassment program?
The harassment program has its own list of required contents. According to the guide, it must include:
- measures and procedures for workers to report harassment to the employer or supervisor
- measures and procedures to report to someone other than the employer or supervisor, if the employer or supervisor is the alleged harasser
- how incidents and complaints will be investigated and dealt with
- how information about an incident or complaint will be kept confidential, unless disclosure is necessary to investigate or take corrective action, or is otherwise required by law
- how the worker who alleged harassment and the alleged harasser will be informed of the results and any corrective action
The program "must be in writing, and must be developed and maintained in consultation with the joint health and safety committee or health and safety representative, if any." It must be reviewed "as often as necessary, but at least annually."
The second bullet is easy to get wrong in a small practice. When the owner-dentist is the only person above the team, a policy that says "report harassment to the owner" leaves no route for a complaint about the owner. The guide says the person could be internal or external, and suggests employers consider options such as a specific person at a business association or a consultant. Whoever you name should not be under the alleged harasser's direct control, which in a small practice usually points outside the team.
How should a dental practice investigate a complaint?
The guide says employers "must ensure that an investigation is conducted into incidents and complaints that is appropriate in the circumstances." It adds that the investigator should not have been involved in the incident and "should not be under the direct control of the alleged harasser," and that employers "should also take appropriate interim measures (such as temporary reassignments or shift changes)" while the investigation runs.
At the end, the employer must ensure the worker who was allegedly harassed "is informed in writing about the results of a workplace harassment investigation and of any corrective action that has been or that will be taken."
Small practices have an obvious problem with impartiality: everyone reports to the owner. That is why it can make sense to line up an external investigator before you ever need one. The guide also notes that an inspector "may order an employer to have an investigation into an incident or complaint of workplace harassment carried out by an impartial person," so planning for outside help is prudent rather than excessive.
Pro Tip: Keep a one-page investigation template with headings (complaint received, interim measures, people interviewed, findings, corrective action and date of written notice). It is quick to set up and makes every future investigation more consistent.
Training your team
The guide says employers "must provide appropriate information and instruction to workers on the contents of the workplace violence policy" and program, and the same applies to the harassment policy and program. It notes that "workers in jobs with a higher risk of violence may require more frequent or intensive instruction" and that "supervisors may need additional information or instruction."
In a practice, that typically translates to front desk staff getting more detailed instruction on de-escalation and summoning help, and office managers or associates who may receive complaints getting instruction on the reporting and investigation steps.
A yearly review checklist for practice owners
Because both policies require at least an annual review, many owners pair the review with a fixed date, such as the start of the calendar year or the practice's fiscal year-end. A practical review covers:
- Re-read both policies and programs; confirm they cover violence and harassment from patients, staff, owners and strangers, and include virtual harassment.
- Recount regularly employed workers and confirm the written and posted requirement is met if you have six or more.
- Redo the workplace violence risk assessment, especially if hours, staffing or layout changed.
- Confirm the harassment program names someone other than the owner or supervisor to receive complaints.
- Confirm consultation with your joint health and safety committee or health and safety representative, if you have one; the guide says their feedback should be documented.
- Check that every new hire since the last review received information and instruction on both policies.
- Date and sign the reviewed versions and keep the previous ones on file.
None of this requires a large HR budget, and the official guide is free to read on ontario.ca. What it does require is someone in the practice treating the annual review as a real appointment rather than a document that renews itself. Read more practice-management articles on the EBIKO Dental blog, or visit ebiko.ca.
How does your practice handle a complaint when the person involved is the owner or lead dentist? Share what has worked for your team.
Sources
- Government of Ontario, Understand the law on workplace violence and harassment (updated 17 August 2026)
Frequently Asked Questions
Q: Does a small Ontario dental office need a workplace harassment policy?
Yes. Ontario's guide says every employer must prepare a workplace violence policy and a workplace harassment policy and review them at least annually, regardless of size. Only the requirement to put the policies in writing and post them depends on having six or more regularly employed workers; the harassment program must be in writing regardless of size, and an inspector can order the policies to be written.
Q: Who should staff report harassment to if the dentist-owner is the harasser?
The harassment program must include a way to report to someone other than the employer or supervisor when they are the alleged harasser. The guide suggests options such as a specific person at a business association or a consultant; the person should not be under the alleged harasser's direct control.
Q: Does harassment by a patient count under Ontario workplace rules?
Yes. The Ontario guide says the harassing or violent person may be someone a worker meets through their job, and it specifically lists patients. Your policies and your workplace violence risk assessment should address patients as a possible source.