Research To Practice Privacy Policy


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.

This Privacy Policy relates to all RTP websites accessible by users and describes the types of information we may collect from users, how we may use it, how users may alter the information they provide and what security measures are in place to prevent unauthorized access of user information.

This Privacy Policy applies only to our RTP websites. The researchtopractice.com website family includes various Internet locations, including but not limited to breastcancerupdate.com, colorectalcancerupdate.com, lungcancerupdate.com, etc. These program sites include content developed specifically for physicians and healthcare professionals.

 

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

PII 

RTP may use PII collected through the Site for any or all of the following purposes.

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.

Other Information

RTP uses non-PII to help us improve the Site, such as by analyzing usage of certain pages or functions on the Site. We may also use non-PII for other purposes, but if any such use involved combining the non-PII with any data so that it became personally identifiable, we would then treat it as PII in accordance with this policy.

 

Information Sharing Policy

PII

RTP may share PII collected through the Site with certain third parties in certain circumstances, including the following.

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.

Other Information 

RTP aggregates non-PII data about users for program-use analysis, program development, activity planning and site improvement. We may also use it for market analysis and provide information from RTP websites in aggregate form, all completely without identification of users, to third parties. For example, we may tell a commercial supporter what percentage of our registered users reside in a particular geographical area or which user practice specialties are named by users.

 

Legal Requirements

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

Acquirers or Assignees: In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of RTP or its assets, we may transfer any and all information that we collect from Site users to the acquiring party or assignee.

Entities Entitled Under Law: We may disclose PII to other entities as we believe to be appropriate in the following circumstances: (i) when required by applicable law, including laws outside a user’s country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Site, including this Privacy Policy; (v) to protect and defend our rights and property; (vi) to protect the interests and safety of RTP or others; and (vii) to permit us to pursue available remedies or limit damages that we may sustain. We have no obligation to notify Site users of such disclosures except as required by applicable law.

 

User Management of PII

Managing Communications from RTP

If a user no longer wishes to receive emails from RTP, that user may opt out of receiving such emails by following the “unsubscribe” directions on the emails, calling us toll free at (800) 648-8654 (9:00 AM - 5:00 PM EST, Monday-Friday) or by sending an email to info@researchtopractice.com with the subject line "Unsubscribe." We endeavor to comply with every request as soon as is reasonably practicable. 

Updating or Correcting PII

Users can review, correct, update or remove PII that they have provided to RTP by visiting the “my account” page on the Site. If that page cannot be located, users are asked to inform RTP by sending an email to info@researchtopractice.com. To protect user information, we will implement such requests only with respect to the PII associated with the particular email address used to send the request, and we may need to verify a user’s identity before implementing a request. We endeavor to comply with every request as soon as is reasonably practicable.

Acceptable Use Practices

RTP also complies with the following acceptable use guidelines:

  • Maintain email addresses of the form info@researchtopractice.com and respond to all email sent to these addresses within 3 business days.
  • Ensure that all RTP communications sent are in good faith, represent accurate and valid information and make no misrepresentations.

 

Protection of Information

In this section of the Privacy Policy we discuss the security measures RTP takes to protect information we have collected from Site users.

Security

RTP uses reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the information under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Site users should exercise caution in sending RTP any information they consider confidential. It is the responsibility of each user to secure copies of passwords and related access codes for our online resources.

Data Integrity and Retention

RTP will retain PII about users for the period necessary to fulfill the purposes outlined in this Privacy Policy or our data retention policies unless a longer retention period is required by law.

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.

Third-Party Sites

The Site may contain links to third-party websites, such as the websites (scientific journals, publications, etc) that are referenced in our CME/CNE activities for further educational research. These linked sites are not under RTP’s control and we are not responsible for the privacy practices or the contents of any such linked site or any link contained in any linked site. If a user provides any PII through any such third party website, that transaction will occur on the third party’s website (not this Site) and the PII provided will be collected by, and controlled by the privacy policy of, that third party. We recommend that users become familiar with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

Collection of PII by Others Through Our Site

We do not allow others to collect the PII of visitors to our Site by tracking the usage of the Site or other websites.

Use of the Site by Minors

This Site may not be used by minors and we do not knowingly collect PII from any individuals younger than age 18. If you are younger than age 18, please do not submit any PII to us, and if you have done so, including by erroneously registering on the Site, please inform us immediately by sending us an email at info@researchtopractice.com.

 

Storage of Health Information

PII that users provide through RTP websites is stored on our database servers at RTP data centers or hosted by third-party technology providers who have entered into agreements with us that require them to observe our Privacy Policy.

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

If a user believes that registration information collected by RTP websites is in error, that user may edit his or her personal profile at any time. A user can directly edit the user profile on our websites. Requesting deletion of a record may result in the removal of that information from the registry, but RTP may keep certain demographic information about users for product improvement purposes.

RTP Employees

RTP employees are required to sign a confidentiality agreement. All employees and contractors must abide by our Privacy Policy, and those who violate that policy are subject to disciplinary action, up to and including termination of their employment and legal action.

 

Privacy Questions or Concerns

For privacy questions or concerns about the ResearchToPractice.com websites, please contact info@researchtopractice.com.

These privacy policies were last updated October 2014.