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Harvard Medical School: Department of Continuing Education
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PRIVACY & SPONSORSHIP POLICY
The Department of Continuing Education ("DCE") has created this privacy statement in order to demonstrate our firm commitment to privacy and sponsorship. The following discloses our information gathering and dissemination practices for this website: http://cmeonline.med.harvard.edu

The DCE and the President & Fellows of Harvard University are the sole owners of the information collected and presented on this site. We will not sell, share, or rent your information to any third party. The DCE collects information from our users at several different points on our website.

ACCME COMPLIANCE
The DCE shall adhere to the policy framework of online Internet activities or enduring material as defined by the Accreditation Council for Continuing Medical Education.

A full description of these policies may be found at the following web addresses:
THE ACCME’S ESSENTIAL AREAS AND THEIR ELEMENTS
ACCME Policies

1. CME activities delivered via the Internet are expected to be in compliance with ACCME Essential Areas, Elements, and Policies.

2. There shall be no CME activities of an ACCME accredited provider on a pharmaceutical or device manufacturers' product website.

3. The learner will be clearly notified that they are leaving the educational website when links from the website lead to pharmaceutical and device manufacturers' product websites. In addition, links may exist before or after the educational content of a CME activity, but shall not be embedded in the educational content of a CME activity.

4. Advertising of any type is prohibited within the educational content of CME activities on the Internet including, but not limited to, banner ads, subliminal ads, and pop-up window ads.

5. At the start of each Internet CME activity, the hardware and software required for the learner to participate will be identified.

6. There will be a mechanism in place for the learner to be able to contact the provider if there are questions about the Internet CME activity.

7. The DCE will adhere to, and inform the learner about its policy on privacy and confidentiality that relates to the CME activities it provides on the Internet.

8. Documentation will be provided upon request that the DCE owns the copyright for, or has received permissions for use of, or is otherwise permitted to use copyrighted materials within a CME activity on the Internet.


SYSTEM REGISTRATION
In order to access the content on the DCE Online CME website, the registrant must first complete a registration form soliciting basic contact information. Information collected will strictly be used for internal tracking purposes. All information collected from our site is the proprietary content of the DCE alone and shall not be shared with any third party. The website is hosted with a trusted Web Presence Provider in Boston, MA - the Beth Israel Deaconess Medical Center (BIDMC).

LOG FILES
We use IP addresses to analyze trends, administer the site, track user's movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

LINKS
This web site contains links to other sites. Please be aware that we are not responsible for the privacy practices of other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.

SECURITY
This site has security measures in place to protect the loss, misuse and alteration of the information under our control. All users must log into the application before any information is available. The information entered by other users is not shared with other users of this system. There is no transmission of patient information involved on this website and therefore no implications to regulation by the Health Care Financing Administration (HCFA) and HIPPA are applicable. Our security features include but are not limited to industry standard 128-bit encryption anytime any sensitive information is passed from your browser to our server. To further increase security, we are hosted in a fully enclosed server farm. We are one of two websites hosted on our dedicated servers at the server farm to limit access to our group of servers. Finally, each DCE and BIDMC developer who does any work on our group of servers must log in, providing a digital record of access to our servers.

Choice/Opt-out
Users who no longer wish to receive our newsletter may opt-out of receiving these communications by replying to unsubscribe in the subject line in the email or email us at support@cmeonline.med.harvard.edu.

ADVERTISING & FUNDING
Funds to operate the DCE Online CME website come from primarily from registration fees paid by course participants. A small percentage of the funds many come from external support for individual online courses. In cases where external support is involved, a clear statement will be made on the title page of the course.
Notification of Changes

If we decide to change our privacy policy, we will post those changes on our homepage located at [http://cmeonline.med.harvard.edu] so our users are always aware of what information we collect, how we use it, and under which circumstances, if any, that we disclose it this information. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, users shall be notified by way of an email. Users will have a choice as to whether or not they give us permission to use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

SHARING
The DCE does not share our user's personally identifiable information with any of our partners. At this time, we do not share any anonymous or demographic information to any outside parties or partners.

EMAIL COMMUNICATIONS
The DCE uses opt-in email to communicate to our users major updates to the system, system outages, and any changes with our pricing structure or privacy policies.
Corrections/Update Personally Identifiable Information

You may change your personally identifiable information at any time. After you log in to our website, click on "My Account". Change your information and then click on the "Save Account" button. If you would like to have us change your information, please send an email to support@cmeonline.med.harvard.edu and we will change it for you. Lastly, you may contact the DCE via telephone by calling (617) 384-8630 during normal business hours.

CONTACTING THE WEB SITE
If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact support@cmeonline.med.harvard.edu.

LEGAL DISCLAIMER
Though we make every effort to preserve your privacy we may need to disclose personal information when required by law or in the good-faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on our Web site.




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