Healthcare

Dental labs: destroying patient data

29 July 2026 · 10 min read · DeSnipperaar

A dental lab works on the instructions of dentists and processes patient data in doing so. The work order carries a name, sometimes a date of birth, the treating dentist and details of the work piece. Alongside this come dental impressions, scans and plaster models that can be linked to a patient. Part falls under the tax retention obligation, part is bound to the work piece and the aftercare, and part should be kept as briefly as possible. This guide shows, by part, what you keep, when it may go and how to destroy it confidentially.

The quick answer: you keep the work order with patient data for as long as it is needed for the work piece and the warranty, while the invoicing falls under the tax seven years. Impressions, scans and models you keep no longer than needed for manufacture and any remake. What may go disappears confidentially and with a certificate.

The processor role towards the dentist

A dental lab does not set the purpose of the treatment itself. You work on the instructions of the dentist, who remains the controller for the patient file. For the data you receive you are usually a processor. That distinction determines who is liable for what and which arrangements you record.

Record those arrangements in a processor agreement with every dental practice you work for. It sets out which data you process, how long you keep it and how you destroy it once the work piece is finished. The dentist works under the WGBO, with a retention period of twenty years for the file. Your period is a different one. You keep only for as long as the work piece and the aftercare require. How the practice sets up its own archive you can read at the dental practice and its WGBO archive.

Retention periods by part

The period differs per type of data. The overview below gives the main line. Count the tax period from the end of the financial year and the other periods from delivery of the work piece.

Part	Starting point	Period
Invoicing and administration	Tax retention obligation	7 years
Work order with patient data	Purpose-bound to the work piece	as long as needed
Dental impressions and scans	As limited as possible	until work piece and remake
Link between patient and work piece	Storage limitation	as briefly as possible
Warranty and aftercare file	Purpose-bound	duration of the warranty
Correspondence and drafts	No retention obligation	clear out at once

Use this as a guideline, not a substitute for the arrangements with the dentist. When in doubt, follow the processor agreement and the practice's instruction. For the tax side, the seven-year retention obligation applies to the invoicing. Other care providers face comparable questions, from the dental practice to the pharmacy with medication files.

Dental impressions, scans and plaster models

A dental impression, an intraoral scan or a plaster model looks like technical material, but as soon as it can be linked to a patient it is personal data. A digital scan with a patient number or name falls under the GDPR just as much as the work order itself. Keep this material no longer than needed for manufacture and any remake within the warranty.

As soon as the work piece has been delivered and the warranty has lapsed, the ground for keeping the link falls away. Physical models with a name on them you clear out confidentially, digital scans you remove from the workstations and backups. That way you avoid managing an archive of traceable impressions for years that you no longer need.

The link between patient and work piece

The sensitive part often lies not in a single piece of data but in the link. A work piece without a name is anonymous, but as soon as the work order, the scan and the invoice can be read together, a traceable whole about a person's mouth and treatment arises. Treat that link as the core of your privacy policy.

Keep the administration you must retain for tax separate from the treatment content that may go. That way you keep the invoice for seven years without holding on to the matching impression or scan for just as long. Whatever you no longer need for the work piece you unlink and clear out.

Digital files, scanners and backups

Many labs work digitally with intraoral scans, CAD files and the control of milling machines and printers. Those files sit on workstations, on a server and sometimes in a cloud service of the supplier. Each of those places may hold patient data that you must be able to clear out one day.

So map where the files sit and who can reach them. Agree with your software supplier how long files are kept and how they are removed when you ask for it. An old scanner or computer you retire does not simply belong with the electronic waste. The drive may still hold scans and names and deserves the same confidential treatment as paper.

How to handle it in 6 steps

1. Split the data into administration, work order, impressions and scans and aftercare.
2. Record the processor role in a processor agreement per practice.
3. Keep impressions, scans and models only for as long as the work piece and the warranty require.
4. Keep the tax administration for seven years, separate from the treatment content.
5. Collect what may go in sealed containers, not in the paper bin.
6. Have it destroyed confidentially with a certificate and record it in your register.

Destroy confidentially with a certificate

Patient data is destroyed confidentially, because it is traceable to a person's mouth and treatment. Paper, plaster models with a name on them and data carriers with scans travel sealed and stay that way until destruction, so the chain is closed. An old workstation drive or backup with scans belongs with it too.

Afterwards you receive a certificate of destruction with the date, quantity and level. That certificate is your proof towards the GDPR and towards the dentist that you acted carefully. Record the destruction in your record of processing. We collect within 20 km of Amsterdam with no call-out charge, work nationwide through pooled collection rounds and charge a fixed price per box or roll container. Drop-off on site is not possible; it works by appointment through collection.

Common mistakes

• Keeping impressions and scans forever. After delivery and the warranty the ground falls away.
• Leaving the link in place. Single pieces of data are less sensitive than a traceable whole.
• No processor agreement with the practice. Without arrangements it is unclear who is responsible for what.
• Plaster models with a name in the ordinary waste. A traceable model on the street is a reportable data breach.
• Keeping no proof. Without a certificate you cannot demonstrate the destruction.

Frequently asked questions

Is a dental lab a processor or a controller?

A dental lab works on the instructions of the dentist and is usually a processor for the patient data. The dentist remains the controller for the file. Record the arrangements in a processor agreement per practice.

How long does a dental lab keep work orders with patient data?

You keep the work order with patient data for as long as it is needed for the work piece and the warranty, after which you clear out the link. The invoicing falls under the seven-year tax retention obligation.

May I keep dental impressions and scans after the work piece is finished?

Keep impressions and scans no longer than needed for the work piece and any remake within the warranty. A digital scan is personal data as soon as it can be linked to a patient. Clear out what you no longer need.

How do I destroy patient data in line with the GDPR?

Confidentially and with a certificate of destruction. Paper, plaster models with a name and data carriers with scans travel sealed and the destruction is recorded in the register.

Conclusion

A dental lab processes traceable data about every patient's mouth and treatment, on the instructions of the dentist. Record your processor role in a processor agreement, keep the administration for seven years and keep impressions, scans and models only for as long as the work piece and the warranty require. Unlink what you no longer need and have it destroyed confidentially with a certificate as proof. That way you protect the patient and the dentist you work for.

Read also: nursing homes: destroying resident records, maternity care: destroying client records, midwifery practices: destroying records and the WGBO and the GDPR retention periods cheatsheet.

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Have patient data collected? Request a quote via desnipperaar.nl. Within a few minutes you have a fixed price, including a certificate as proof.