We maintain physical, electronic and procedural safeguards to protect information and while no data transmission over the Internet is 100% secure from intrusion, we will use commercially reasonable efforts to ensure the protection of your information, continue to assess new technology for protecting information and, when appropriate, upgrade our information security systems. In this legal and technical environment, we cannot fully ensure your personally identifiable information will not be disclosed to third parties. For example, we may be compelled to disclose your information to a governmental agency or a court; or third parties may unlawfully intercept or access transmissions or private communications. Additionally, we may (and you authorize us to do so) disclose any personally identifiable information about you to your sponsoring Registered Member, to private entities, law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate to investigate or resolve possible problems or inquiries, to protect our business and assets and to comply with our legal and regulatory obligations.
This Privacy Statement is intended to disclose our privacy practices and inform you as to:
We collect information about you when you visit and use our Website, when you enter or input information, whether during the registration process, in the course of entering, exchanging or transmitting information or otherwise in connection with your activities and use of our Website. If you are a registered user, you acknowledge and also consent to our tracking your activities and use of our Website.
- the kinds of information we collect from users of our Website and how that information is collected;
- how the information is used by us;
- whether we disclose information to third parties;
- how you can access, update or delete any of your information we have collected; and
- the mechanisms we have implemented to protect your personal information.
You can visit the publicly available portions of our Website and learn about the Healthcare Leadership Council ("HLC"), its work and services, obtain general information and find out how to contact us – all without giving us any personal information about yourself. In general, for purposes of this Privacy Statement, when we use the term "your information", "personally identifiable information" or similar terms, we mean information that is personally identifiable with a specific individual or about a specific individual’s current or former relationship with the HLC or its Registered Members.
If you would like to know more about cookies or other aspects of the information we collect and how we do so, please see our Frequently Asked Questions at the end of this page for more detailed information.
- keeping count of your return visits to our Website;
- accumulating and reporting aggregate, statistical information in connection with our Website; and
- determining which features users like best.
Although we may track the numbers of visitors to our Website to inform us on how best to update the Website and enhance the experience for visitors, personally identifiable information is not extracted in this process. We use information on an aggregated basis to help us operate our Website, enhance and improve our service, improve the look of our Website and display information, including promotional and other information. In order to measure the use of our Website and make improvements to it, information may be gathered on users' visits to the Website. This involves logging domain names of visitors and any web sites they may have been directed from. This information is aggregated for monitoring. We may also use the information you provide us to tailor your experience at our Website, to display content we think may be of interest you, or to let us customize what you see when you visit our Website according to your preferences. When you first become a registered user and periodically thereafter when we request that you provide us with personally identifiable data, we will give you the opportunity to "opt out" of receiving future communications from us. Of course you may opt out of receiving such communications at any time by simply notifying us at 50StatePrivacyStudy@hlc.org.
Whether you are an individual or a business, in order for you to use our Website as a registered user, we may collect or ask you to provide us with certain information about you and your sponsoring Registered Member, for security purposes, in connection with your permitted use of our Website. For example, we may ask you to provide us with personally identifiable information such as your name, address, telephone number, e-mail address, and your relationship with or to the Registered Member. This assists us to authorize you to access the features of the Website that are available only to registered users. This information also helps us ensure we are able to securely identify you as an authorized user. We also reserve the right to verify and confirm any information we obtain from you or through your use of our Website to ensure the proper, efficient and secure operation of our Website. If you would like to know more about the technical aspects of the information we collect and how we do so, please see our Frequently Asked Questions section at the end of this page for more detailed information.
Unless you have registered directly with the HLC, your sponsoring Registered Member, not the HLC, is responsible for determining which individuals are permitted to use our Website under their authority and for providing those individuals, including you, with the necessary IDs. Only we can change or, if applicable, your sponsoring Registered Member, can request us to change, your assigned IDs. However, you will be able to change any personal information you have given us in order to reflect updates when they occur. Also keep in mind that in addition to our rights, your sponsoring Registered Member will also have the right to request us to suspend, cancel and/or revoke your right to use our Website at any time, for any reason, and we will immediately terminate your right to use the Website as a registered user at their request. We always reserve the right to ask you to provide evidence of proper authorization from a Registered Member at any time and if we determine such authorization or permission has not been properly obtained, we may immediately and without notice, discontinue your use of our Website. Once we terminate your right to use the Website, we will only retain your information for archival and audit purposes or as may be required by law or regulation and we will not use your information for any other purposes.
The personally identifiable information you provide to us, as well as any information, personal or otherwise, that you create and which may be saved in connection with your use of our Website, is used to provide you with better service. It allows us to save you time and better understand your needs. It also helps us learn more about your preferences and the information, materials and services that may be of interest to you. For example, we track your information to help us respond to requests for assistance, produce reports, maintain quality control, administer and manage the Website and our operations, and whenever it may become necessary or appropriate, to contact you concerning your use or other activities associated with our Website.
The personally identifiable information we collect and store generally consists of information gathered from your registration, data input, forms and other information you provide us, electronically, by phone, telecopier, in writing, in person or by any other means and information about your transactions and experience with the HLC and our Website.
While information is critical to our ability to provide high quality service to you, our most important asset is the trust that our users and Registered Members place in how we provide that service. Keeping information secure, and using it only as our users would want us to, is a top priority for all of us. Consequently, our privacy standards are designed to ensure that we:
- Collect and use your personally identifiable information only as necessary to deliver high quality service, to administer our Website and to let you know of relevant products and services;
- Protect the information you share with us, maintaining strict standards of confidentiality. Any employee found violating our standards will be subject to our disciplinary processes;
- Advise you, and all of our registered users, in easy to understand language, now and periodically, how they may remove their names from lists we may share with non-affiliated third parties. Of course, you, like any of our users, can contact us any time to have your name removed from such lists.
- Require any other organization that we retain or engage to provide support services for us to conform to our Privacy Statement and allow us to audit for compliance.
- Exchange information about our registered users, necessary for security and risk management and to prevent fraud and any other activities we may be required to monitor and report under applicable laws and regulations;
- Make every effort to keep your information up to date and accurate. On our Website we will provide an easy to use mechanism to allow registered users to access and update their personally identifiable information. This will you to review and notify us about any inaccuracies or errors -- which we will promptly correct.
We will always seek to improve our Website and our service to you. In accomplishing these objectives, we may buy or sell a business or business unit, we may reorganize for financial or tax reason or one or more of our businesses or business units may merge with or be acquired by another business. If these or any similar types of transactions occur, we may transfer some or all of your information as a part of that transaction so that the service being provided to you may continue.
- we have your consent (you "opt-in") to share your information;
- we have retained companies to work with us or on our behalf to provide goods or services you have requested;
Our Website may contain references and links to Third Party Sites, other organizations or even displays which promote the availability of other goods and services we think may be of interest to some or all or our users and Registered Members. We may use also third parties to help us with the displays on our Website and any of our HTML-formatted newsletters, bulletins or materials. Often these third parties employ cookie and Web bug technologies to measure effectiveness (see our Frequently Asked Questions for more information about these technologies). You should be aware that different rules may apply to the collection, use or disclosure of your information by third parties in connection with any other sites you encounter on the Internet. Cookies used by these third parties are theirs -- not ours -- and even if we have a business or other relationship with that third party, we do not control those sites or those third parties and we encourage you to investigate and ask questions before disclosing information to any such third parties.
Some aggregate user data (not personally identifiable data) may be shared with third party companies to enhance and improve the operation and relevance of our Website. We do not give any personally identifiable information to them as part of this relationship. Use of their tracking technology is subject to their own privacy policies.
If you have questions about our Privacy Statement please continue to read through our Frequently Asked Questions section. If you still cannot find the answer to a question related to our Privacy Statement or if you do not understand any of the information about how we collect, maintain, use or share your personally identifiable information, you may contact us directly at 50StatePrivacyStudy@hlc.org.
Privacy Statement – Frequently Asked Questions
Q: What steps has the HLC taken to ensure the privacy and security of your personally identifiable information on our Website?
A: A top priority is to protect the confidentiality and integrity of our registered users’ personally identifiable information. The HLC attempts to have reasonable and appropriate safeguards which include:
1. Firewalls -- Our Website has in place an Internet firewall designed to securely separate the Internet from the computer systems and databases associated with our Website. Transmissions and information coming from external customer computers via the Internet flows through a series of safety checkpoints on its way to our internal systems so that only authorized messages and transactions enter our computer systems.
2. Monitoring -- the HLC monitors internal systems to ensure that there has been no security attack or attempted break-in. We also arrange for regular independent security checks on our computer systems to ensure our standards are being complied with.
Q: What is an IP address and what is it used for?
A: Every Internet user is identified by a unique code known as an Internet Protocol (IP) address. If you have a static IP address, you have the same number each time you connect to the Internet. If you have a dynamic IP address, a number is assigned to your computer from a pool of addresses established by your Internet service provider (i.e., your ISP), which can result in your computer having a different IP address each time you use the Internet. Technology enables us to use IP addresses to identify your computer and we collect IP addresses for security and system administration purposes, as well as for compiling and reporting aggregate, non-personally identifiable information.
When you visit our Website, our technology logs your IP address, but we do not link this IP address to your personally identifiable information. This means that although your activity using your particular IP address during any particular Internet session is logged, you remain anonymous to us. We can and will use IP addresses to identify you when we believe it is necessary to enforce compliance with this agreement, to protect us, our Website, our technology, our business and assets, our suppliers, customers and other users, and any other parties, from actual, potential or threatened harm or damage or to comply with applicable law, regulation or the order of any court, regulatory agency or law enforcement official.
Q: What are cookies and web bugs?
Your Internet browser has a feature called "cookies." A cookie is a small piece of information that is stored in your browser by a web server. Cookies can only be read by the site that placed the cookie on the hard drive of your computer. However, cookies tell us nothing about who you are unless you specifically give us personally identifiable information. You do not need to have cookies turned on to just visit our Website, although logging in and active participation and use of our Website may require cookies. In addition, you may elect not to allow cookies to be collected by selecting certain options on your web browser.
Cookies are text files stored on your computer’s hard drive when you visit our Website. Most computer operating systems provide users with the option of disabling this function if they choose to do so. Cookies contain unique identifying numbers that allow the technology in our Website to identify the file that is on your computer’s hard drive and take note of your previous visits to our Website. Cookies will not be used by us to track your personal activities or share such activities with any third party.
As you browse the World Wide Web on the Internet, cookie-enabled websites will send cookies to your browser, along with pages that are displayed. Your browser probably has options that will let you control whether it will accept cookies, reject cookies, or notify you each time a cookie is sent to you and ask if you wish to accept this particular cookie or not. There are also different types of cookies. One will store information and can be used for a number of administrative purposes. Another will allow you to use your user name and password to log onto, and remain on, our Website for a session -- which is a visit to our Website -- that lasts until you choose to leave by closing your browser.
A: Web Bugs
We use electronic images known as Web bugs – these are sometimes called single-pixel GIFs, transparent GIFs, or clear GIFs -- that allow us to track general user traffic patterns. The HLC also automatically receives and records information from our servers and from your browser, including your IP address, the time, and information about the page you requested.
Q: What if I don’t want to accept any cookies?
A: If your browser is set to reject cookies, cookie-enabled websites will not recognize you when you return. This provides you with anonymity, but it also makes it very difficult to offer you customized services. It is also less secure than using cookies, because all of your specific data must be sent to our Website each time you view a page. Accepting cookies means your private data can stay at the Web server, and the only information transmitted over the Internet is your ID cookie.
If your browser is set to accept cookies, any cookies that are sent to your browser are stored in your computer for a period of time. There are a few different types of cookies. A "session" cookie is stored only in your computer's working memory (RAM) and only lasts for that particular browsing session. When you close all of your browser's windows (i.e., you log off), or when you shut down your computer, the session cookie disappears forever.
You will need to support cookies to log on to our site with your IDs (i.e., your user identification code and password).
Q: How can I enable cookies?
A: Please follow the instructions for your browser type and version to enable cookie settings. If you are using AOL, please check your browser version and follow the appropriate instructions. For additional assistance or if are not sure how to proceed with enabling cookies for your particular computer browser type and version, please contact your Internet Service Provider (ISP).
Q: What is a firewall and what does it do?
A: An Internet Firewall is made up of a combination of hardware and software which is designed to securely separate the Internet from internal computer systems and databases. At the HLC, data coming from users’ computers via the Internet flows through a series of safety checkpoints on its way to our internal systems. Data is encrypted between our registered users and internal systems to with commercially available technology to protect it from unauthorized disclosure or modification.
Q: What does security on the Internet mean?
A: Security on the Internet means that transmissions sent from one source to another maintain their confidentiality and integrity. Confidentiality means that unauthorized users cannot read any transmissions sent from one party to another. Integrity means that messages are not altered during transmission.
A: Cookies allow us to enhance your navigation and use of our Website and improve its performance.
Q: Are cookies secure?
A: The security and confidentiality of your personally identifiable information will not be compromised when you accept a cookie from our Website. Cookies from our Website will be encrypted and cannot be read by another web site. The cookie cannot be used to access any data on your computer. Computer viruses, at least those known today, are not passed through cookies.
May 22, 2013