CAQH Privacy Policy

CAQH PRIVACY POLICY

EFFECTIVE DATE:  March 2, 2015

1. CAQH SITES AND SERVICES

The Council for Affordable Quality Healthcare, Inc. (“CAQH”) is committed to helping to reduce healthcare administrative burdens, which includes protecting your privacy. The information we collect through our websites and services helps us to provide you with information specific to your needs and interests. This privacy policy (the “">Privacy Policy”) governs your access to and use of all current and any future CAQH websites and the services offered on those websites.

CAQH currently operates the following websites (collective “Sites”):

  • The CAQH organization website (http://caqh.org), including various subdomains.

 

CAQH currently offers the following services through our Sites (collectively, “Services”):

  • CAQH ProView™ (formerly Universal Provider Datasource® (UPD))
  • SanctionsTrack
  • EnrollHub
  • COB Smart
  • CAQH CORE—Committee on Operating Rules for Information Exchange
  • CAQH Index (formerly the U.S. Healthcare Efficiency Index)

 

For our various Services, additional terms may apply. Additional Service-specific terms may be accessed through the Terms of Service.

Additionally, this Privacy Policy is to be read along with any separate service agreement(s) that you may have in place with CAQH. If there is a conflict between that agreement and this Privacy Policy, the terms of the service agreement will control.

By accessing any of our Sites or Services, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Sites or Services. Each time you use our Sites or Services, the current version of the Privacy Policy will apply. Accordingly, whenever you use our Sites or Services, you should check the date of this Policy (which appears at the top) and review any changes since the last version. This Privacy Policy is applicable to all visitors, registered users, and all other users of our Sites or Services.

The provisions contained herein supersede all previous notices or statements regarding our privacy practices with respect to the Sites and Services. We post an effective date on the Privacy Policy so please check back periodically to review the current policy.

2. HOW DOES CAQH GATHER AND USE INFORMATION?

CAQH Content” means including, without limitation, characters, data, images, photographs, animations, video, audio, music, text, and applets on the Sites, and any and all other material and information provided by CAQH or its third party providers that You see on the Sites and/or through the Services. Any content that you provide to CAQH regarding feedback or ideas on the Services shall become CAQH Content.

Content” shall mean CAQH Content, Third Party Data, and User Submitted Data collectively.

Personal Information” includes any information that identifies you, would enable someone to contact you, or that describes your relationship with CAQH.

Third Party Data” shall mean data that CAQH obtains from third party sources.

User Submitted Data” shall mean any information that you submit to CAQH through the Sites or Services such as provider contact information, payment information or certifications, and includes Personal Information that you submit directly to CAQH.

The use of User Submitted Data is subject to this Privacy Policy and the Terms of Use (including any Site-specific Terms associated with a particular Service) in effect at the time we use such information. This section provides details about how CAQH gathers and uses User Submitted Data.

(a) Cookies.  Cookies are pieces of data assigned by a web server that uniquely identify the browser on your computer. CAQH may attempt to install cookies when a user arrives at any of our Sites or uses our Services. Cookies enable our systems to gather information about your navigational patterns through the Sites and Services. Viewers have the option to accept or disable cookies at any time through their browsers. Visit the “help” portion of your toolbar for more information. If you block or refuse to accept cookies, or delete cookies between visits to any of our Sites, you may not be able to access or use certain features or functions of our Sites or Services.

(b) User Analytics.  We may collect general statistics to track user trends on our Sites and Services. These statistics may include hits to our server, the types of browsers used to access our Sites, page views, and navigational patterns. The information that is collected in this manner does NOT provide us with any Personal Information about our users. It helps us track “where” our users are coming from. This allows us to pinpoint high traffic areas and determine the most effective ways to communicate with our users. We may use this statistical information for research and commercial purposes and to develop improvements to our Sites and Services.

(c) Information Users Provide to CAQH.  We collect and store User Submitted Data when you register to use our Sites or Services, utilize the Services on our Sites, ask a question, complete a form, conduct a transaction, or send us an email. To use our Services, you will be required to submit certain User Submitted Data, including Personal Information. If you do not provide the requested information, you may not be able to access or use some of the features and functions of our Sites and we may not be able to provide you with our Services. For administrative and security purposes, such as to prevent the introduction of viruses and hackers into the CAQH site, we may collect and retain information, such as IP addresses.

We may use your User Submitted Data internally, among other things, to communicate with you, to provide information or Services to you, to contact you directly about Services that you have purchased, and for our research or business purposes.

We may also combine your User Submitted Data with Third Party Data to provide our Services.

Users who subscribe to certain of our Services will be required to provide certain User Submitted Data, including Personal Information that will be shared with other Users of the Services. The types of information collected through such Services include:  

  • CAQH ProView TM (formerly Universal Provider Datasource® (UPD)):  Provider practice information including demographic and credentialing data.
  • EnrollHub:  Provider practice routing information for payment and remittance advices.

In addition to this Privacy Policy, if you have an agreement with a third party user of CAQH Services (“Service Recipient”) and provide information to or through the Service Recipient, that agreement may also govern the collection, use and disclosure of your User Submitted Data through this Site.

3.  WHAT SECURITY PROCEDURES DOES CAQH USE TO PROTECT PERSONAL INFORMATION?

CAQH uses physical, electronic, and administrative safeguards to assist us in preventing unauthorized access, maintaining data accuracy, and correctly using User Submitted Data. Information that is sent to us through our Sites and Services is secured by encryption. Because email transmissions are not secure, we encourage you to use encryption when sending us any User Submitted Data by email, or to use another means of transmitting the information to us.

Access to User Submitted Data through our Sites and Services is limited to registered persons who are required to use unique passwords to obtain access. We contractually prohibit these persons from using your User Submitted Data other than for the purpose of using our Services (unless otherwise authorized by you).

CAQH will retain User Submitted Data for as long as your account is active or as needed to provide you with our Service. If you wish to cancel your account or request that we no longer use your information to provide our Services, please contact us at info@caqh.org. We will retain and use User Submitted Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

4. WILL CAQH DISCLOSE THE USER SUBMITTED DATA WE COLLECT TO THIRD PARTIES?

CAQH may share User Submitted Data, including Personal Information contained within User Submitted Data, as described below.

(a) Affiliated Businesses We Control.  We may share User Submitted Data with the affiliated businesses we control to make sure that your experience with us is as seamless as possible and that you have the full benefit of our Services. The use of User Submitted Data by such controlled affiliates remains subject to this Privacy Policy.

(b) Agents.  We employ other companies and individuals to perform functions on our behalf. Some examples of such functions include operating and hosting our service offerings, supporting our information technology infrastructure, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing payments, and providing customer service. We share User Submitted Data with these agents as we deem necessary for such third parties to perform their functions. We may also provide aggregate statistics about our customers, traffic patterns and related site information to reputable third party vendors, but these statistics do not include Personal Information.

(c) Unaffiliated Third Parties.  CAQH may from time to time disclose User Submitted Data to third parties as set forth in Section 4(h) below, and in connection with initiatives or activities consistent with our mission to simplify healthcare administration. 

(d) Protection of CAQH and Others.  We may disclose User Submitted Data collected from you to (a) comply with the law, applicable regulations, governmental and quasi-governmental requests, orders or subpoenas directed to us or our affiliates; (b) protect and defend our rights or property or the rights or property of other users of our Sites and Services including the enforcement of our Terms of Use or other agreements; (c) respond to an emergency or protect the personal safety of users of our Sites or Services, or the public; or (d) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection).

(e) Change of Control.  In the event that a third party acquires all or a substantial portion of CAQH’s business, whether such acquisition is by way of merger, liquidation, dissolution, consolidation or sale of all or a substantial portion of our business, trade or assets, informational Content (including User Submitted Data) will be transferred to the acquiring third party. By using our Site or Services, you consent to the sale and transfer of your User Submitted Data as described in this paragraph.

(f) Public Areas of our Site or Services.  If you provide any User Submitted Data to CAQH for posting in areas of our Sites or through our Services that may be publicly viewed (e.g., blogs or messaging features to the extent available), your information will be available to third parties who use our Sites or Services. Please be cautious when using public areas of our Sites or Services.

(g) Authorized by User.  We may disclose User Submitted Data we collect from you if you request or authorize it.

(h) As Part of the Services. CAQH may disclose User Submitted Data, which you provide as part of your membership in the Services to Service Recipients and other CAQH customers in accordance with any Terms of Service relating to each applicable Service. Access to such User Submitted Data through our Services is limited to registered users who are bound by agreements governing their use of Content (subject to any agreement you may have directly with Service Recipients relating to their use of your Personal Information).

(i) Privacy Policy.  User Submitted Data may also be disclosed as otherwise described in this Privacy Policy.

5. EXTERNAL LINKS

Other companies or organizations may have links to their websites or services through our Sites or Services. We are not responsible for how these other companies or organizations collect, use, disclose, or secure the information that you provide them. If you choose to access a third party website or service linked to one of our Sites or Services, you do so at your own risk and subject to any terms of service or privacy policy (if any) associated with such third party websites.

6. COLLECTION OF INFORMATION FROM CHILDREN

CAQH does not direct any of our content specifically to children. We do not knowingly collect or use Personal Information from individuals under eighteen (18) without obtaining verifiable consent from their parents or a guardian. If we learn that a user is under 18 years of age, we will promptly delete any Personal Information we have collected about that user. If you are under the age of 18, please do not send us any information about yourself.

7. DO NOT TRACK

CAQH does not respond to web browser “do not track” signals. As such, your navigation of our Sites and use of the Service may be tracked as part of the gathering of the general User Analytics collected by CAQH. If you arrive at our Sites by way of a link from a third party site that does respond to “do not track” requests, the recognition of any “do not track” request you have initiated will end as soon as you reach our Sites.

8. ACCESSING YOUR INFORMATION

On some of our Sites or to use our Services, you may be required to register in order to access your information. You may be required, under certain agreements you may have with health plans, hospitals or other third parties, to ensure that your information with CAQH is up-to-date and accurate. You may view and edit your User Submitted Data by accessing the Site and supplying your username and password or other required authentication. Your username and password or other authentication allows access to your information so you are responsible for the disclosure of your information to anyone using your username and password. Please protect these security devices and notify us immediately if they have been lost, stolen or misappropriated. 

9. UPDATING OUR POLICY

CAQH may at our sole discretion revise this Privacy Policy at any time. If any material changes are made, we will notify you by displaying a prominent announcement on our Sites prior to the new Privacy Policy taking effect. Depending on the Service, we may display notice of a change for a reasonable period. If you continue to use our Sites and Services following the posting of changes to this Privacy Policy, you will be deemed to have accepted the changes. Any revised privacy policies posted by CAQH will supersede all previous notices or statements regarding the Sites or Services.  

10. OPT-OUT / INFORMATION CORRECTION OR REMOVAL

If any of the information that we have about you is incorrect or you wish to have information (including Personal Information) removed from our records please contact us at ITSecurity@caqh.org.

Additionally, if you prefer not to receive marketing messages from us, please let us know by clicking on the unsubscribe link within any marketing messages that you receive or by sending a message to us at info@caqh.org. This election will not affect your receipt of messages from us associated with the Services.

11. INTERNATIONAL USERS

CAQH is headquartered in the United States of America. Personal Information that you provide may be accessed by CAQH or transferred to CAQH in the United States or to our affiliates, partners, merchants, or service providers elsewhere in the world in accordance with this Privacy Policy. By visiting our Sites or using our Services, you consent to this transfer. You explicitly acknowledge and consent to the fact that Personal Information will be stored and processed in the United States and will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Information.

12. CERTAIN CALIFORNIA RIGHTS

If you are a California resident, California Civil Code Section 1798.83 requires select businesses to disclose policies relating to the sharing of certain categories of your Personal Information with third parties. If you reside in California and have provided your Personal Information to CAQH, you may request information about our disclosures of certain categories of Personal Information to third parties for direct marketing purposes. Such requests must be submitted to us at by email at info@caqh.org.

Within thirty (30) days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. CAQH reserves the right not to respond to requests submitted other than to the address specified in this Section.

13. CONTACTING US

The Sites and Services are owned and operated by CAQH.  If you have questions or suggestions regarding this Privacy Policy or our privacy practices please send an email message to: info@caqh.org.

© CAQH 2015. All rights reserved.

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