Research To Practice (RTP) websites (http://www.researchtopractice.com) are produced by RTP and referred to in this policy as the “RTP websites” and “the Site.” We want to be sure that visitors to the Site understand our practices and how we strive to protect any personal information collected by the Site.
Types of Information Collected from Site Visitors
Information collected through the Site may include personally identifiable information (PII), which is information that identifies an individual personally, such as first and last name, postal address, email address or telephone number. For example, a free registration process is required for visitors to view detailed content and access the full range of services offered by the Site. This registration requires an email address, clinical specialty and demographic information. When users participate in a continuing medical education (CME) or continuing nursing education (CNE) activity provided by RTP, they must provide their name, street address, telephone number(s), fax number, email address, degree and specialty. A National Provider Identifier (NPI number) might also be required for participation in a CME or CNE activity related to a federally mandated Risk Evaluation and Mitigation Strategy for which participant tracking is required by the US Food and Drug Administration (FDA).
Note, only those registering for CME/CNE, subscription services or meeting attendance are asked to provide identifying information, such as name, contact information, etc. On our registration screen we clearly label which information is required for registration and which information is optional and may be given at the user's discretion.
The Site also automatically collects information about Site visitors that is not PII but relates to an individual’s use of the Site. Non-PII is aggregated information, demographic information and any other information that does not reveal specific identities. Non-PII is “passively” collected through browser navigation tools, such as cookies and pixel tags. These types of technology enable the Site to compile statistics about the daily number of Site visitors or specific page requests and do not identify individuals other than by IP address, which is the Internet Protocol address of the computer used to access the Site. RTP does not permit unaffiliated third parties to track information about users of the Site.
More About Cookies
A cookie is a small data file that a website transfers to a user's hard drive when the user visits the website. A cookie file can contain information such as a unique ID that the Site uses to track the pages visited, and it is a standard method of registering website user preferences. These preferences are stored in a file on the user’s computer hard drive. We also use “analytical cookies.” These allow us to recognize and count the number of visitors to the Site and to see how visitors move around the Site when they’re using it. This helps us improve the way our website works, for example, by making sure users find what they need easily.
RTP websites use both persistent and session cookies. Persistent cookies are cookies that stay on a user’s computer until their expiration date or until they are manually deleted. Session cookies are deleted automatically when a user leaves a website to visit another one or shuts down the web browser.
Users can set their browser to accept all cookies, to reject cookies or to notify them whenever a cookie is offered so that the user can decide each time whether to accept it. However, refusing a cookie may in some cases preclude use or negatively affect the display or function of the Site or certain areas or features of the Site. To learn more about cookies, including how to enable cookies, change browser settings and find and delete cookies from a hard drive, users may refer to web browser help menus or visit www.allaboutcookies.org.
By using RTP websites you are deemed to unambiguously agree to RTP use of any cookies that you do not disable.
Information from Outside Sources
In order to verify the licensure status and identity of physicians or other healthcare professionals who register on RTP websites, RTP may also collect information from other sources about registered users.
Use of Information
Responses to Requests: We may use PII about a Site user to respond to that user’s requests, such as questions about CME/CNE programs, and to provide the user with benefits offered by programs in which he or she has enrolled.
Test Scoring: We use PII to score post-tests and/or to issue certificates of completion documenting participation in a CME/CNE activity.
Communication with RTP Subscribers: If a Site user joins our mailing list (by agreeing to be contacted with special offers and informed of special events, etc), we will send that person information on such offers, events and other products, programs or services that we believe may be of interest. A user may opt out of receiving such communications, as described in those communications and in the section below on user management of PII.
Internal Business Purposes: RTP uses PII about Site visitors for our internal business purposes, including in particular to help us determine usage of CME/CNE programs, events and other offerings and to track the acceptance of program offers and help us improve our services. We also use PII for related internal purposes, such as data analysis, audits, enhancing the Site, identifying usage trends and other outcomes analysis.
Information Sharing Policy
Accrediting Organizations: RTP may report user participation to and share personal information, including name, address and NPI number, with organizations such as the Accreditation Council for CME (ACCME) or organizations that are approved by the FDA to collect information on CME/CNE related to a mandated Risk Evaluation and Mitigation Strategy.
Educational Partners/Providers: On occasion, a third-party education provider or partner of a CME/CNE activity on the Site (provider/partner) will ask us for a list of the people who participated in a particular CME/CNE activity that the provider/partner prepared or accredited, for the provider/partner’s record-keeping purposes only. In response to such a request, we will provide the provider/partner with the name, street address, email address, profession and specialty of each person who participated in that CME/CNE activity.
Commercial Interest/Commercial Supporter: A “commercial interest” is defined by the ACCME as any entity producing, marketing, reselling or distributing healthcare goods or services consumed by or used on patients. A commercial interest that provides support to an RTP CME/CNE activity is referred to as “the supporter.” We may disclose personal information to the supporter so that it can comply with applicable laws. For example, if the supporter asks RTP for personal information that it needs to comply with the federal “Sunshine Act,” we are obligated to provide relevant user PII.
We do not share PII with or sell PII to any unaffiliated third parties or commercial supporters for their own marketing purposes or for any purpose outside what is outlined above.
Companies and People Who Work for RTP: RTP contracts with other companies and individuals to help us provide services. For example, we may host some of our RTP websites on another company's computers, hire technical consultants or work with other companies to remove repetitive information from customer lists, analyze data, provide marketing assistance and provide customer service. In addition, we may validate a user’s licensure status as a healthcare professional and other information using available databases that list licensed healthcare professionals.
In order to perform their jobs these other companies may have limited access to some of the personal information we maintain about our users. We require all such companies to comply with the terms of our privacy policies, to limit their access to any information to the minimum amount necessary to perform their obligations and not to use the information they may access for purposes other than fulfilling their responsibilities to us.
RTP may release registration information when we believe such release is required by law. If we discover that a third party inadvertently disclosed personal information about any of our users, we will take immediate action to prevent further occurrences.
Other than in the cases described in this policy, RTP will not release PII to a third party without the user's consent. Also, if we ask consent to release information to a third party, we will make our best efforts to clearly define and limit the scope of that consent.
Other Legal Notifications
User Management of PII
Managing Communications from RTP
Updating or Correcting PII
Acceptable Use Practices
Protection of Information
Data Integrity and Retention
RTP has implemented technology and security policies, rules and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction and accidental loss. We also protect user information by requiring that all RTP employees and others who have access to or are associated with the processing of user data respect user confidentiality.
RTP uses security methods to determine the identity of its registered users so that appropriate rights and restrictions can be enforced for that user. Reliable verification of user identity is called authentication. RTP uses both passwords and usernames to authenticate users. Users are responsible for maintaining their own passwords and usernames.
Collection of PII by Others Through Our Site
Use of the Site by Minors
Storage of Health Information
RTP maintains a firewall to prevent individuals from accessing Site information without authorization. Data centers are physically secure and protected from unauthorized access by unauthorized persons. Physical access to the servers requires individual authorization and authentication.
Information in our data centers is backed up routinely in order to aid in the recovery of information in the event of accidental damage of information or a natural disaster. The backup media are stored in a physically secure storage facility.
Correction of Information
Privacy Questions or Concerns
For privacy questions or concerns about the ResearchToPractice.com websites, please contact email@example.com.
These privacy policies were last updated October 2014.