Wednesday, April 1, 2015

Suggested improvements for a medical journal privacy policy


After I gave the New England Journal of Medicine a failing grade for user privacy noting that their website used more trackers than any other scholarly journal website I looked at, the Massachusetts Medical Society asked me to review the privacy policy for NEJM.com and make changes that would improve its transparency. On the whole their website privacy policy is more informative and less misleading than most privacy policies I've looked at. Still, there's always room for improvement. They've kindly allowed me to show you the changes I recommended:


Last updated: April 1, 2015

Governing Principles 

NEJM.org is owned and operated by the Massachusetts Medical Society (“MMS”). We take privacy issues seriously and are committed to protecting your personal information. We want to say that up front because it sounds nice and is legally meaningless. Please take a moment to review our privacy policy, which explains how we collect, use, and safeguard information you enter at NEJM.org and any of our digital applications (such as our iPhone and iPad applications). This privacy policy applies only to information collected by MMS through NEJM.org and our digital applications. This privacy policy does not govern personal information furnished to MMS through any other means.


WHAT INFORMATION DO WE COLLECT?

Information You Provide to Us
We will request information from you if you establish a personal profile to gain access to certain content or services, if you ask to be notified by e-mail about online content, or if you participate in surveys we conduct. This requires the input of personal information and preferences that may include, but is not limited to, details such as your name, address (postal and e-mail), telephone number, or demographic information. You can't use secure communications to give us this information, so you should consider anything you tell us to be public information. If you request paid content from NEJM.org, including subscriptions, we will also ask for payment information such as credit card type and number. Our payment providers won't actually let us see your credit card number, because there are federal regulations and such.
Information That Is Automatically Collected
Log Files
We use log files to collect general data about the movement of visitors through our site and digital applications. This may include some or includes all of the following information: the Internet Protocol Address (IP Address) of your computer or other digital device, host name, domain name, browser version and platform, date and time of requests, and the files downloaded or viewed. We use this information to track what you read and to measure and analyze traffic and usage of NEJM.org and our digital applications. We build our site in such a way that this information is leaked to our advertisers, our widget providers, our analytics partners, the advertising partners of our widget providers, all the ISPs that connect us, and government entities such as the NSA, the Great Firewall of China, and the "Five Eyes" group.
Cookies
We use cookies to collect information and help personalize your user experience us make more money. We store minimal personally identifying information ten tracking identifiers in cookies and protect allow our partners to access this information. We do not store complete records or credit card numbers in cookies. We don't put chocolate chips in cookies either. Even if they're the other kind of cookies. Because we read about the health effects of fatty foods, in NEJM of course. You can find out more about how we use cookies at our Cookie Information page which is a separate page because it's more confusing that way.
Most web browsers automatically accept cookies. Browsers can be configured to prevent this, but if you do not accept any cookies from www.NEJM.org, you will not be able to use the site. The site will function if you block third party cookies.
In some cases we also work with receive services or get paid by third party vendors (such as Google, Google's DoubleClick Ad Network, Checkm8, Scorecard Reasearch, Unica, AddThis, Crazy Egg, Flashtalking, Monetate, DoubleVerify, and SLI Systems) who help deliver advertisements on our behalf across the Internet, and vendors like Coremetrics, Chartbeat and Mii Solutions, who provide flashy dashboards for our managers. These vendors may use cookies to collect information about your activity at our site (i.e., the pages you have visited) in order to help deliver particular ads that they believe you would find most relevant. You can opt out of those vendors' use of cookies to tailor advertising to you by visiting http://www.networkadvertising.org/managing/opt_out.asp. Except for Checkm8, Scorecard Reasearch, Unica, Crazy Egg, Monetate, Coremetrics, Chartbeat, Mii Solutions and SLI Systems. And even if you opt out of advertising customization, these companies still get all the information. We have no idea how long they retain the information or what they do with the information other than ad targetting and data dashboarding.
Clear Gifs (Web Beacons/Web Bugs)
We may also use clear gifs which are tiny graphics with unique identifiers that function similarly to cookies to help us to track site activity. We do not use these to collect personally identifying information, because that's impossible. We also do not use clear gifs to shovel snow, even though we've had a whole mess of it. Oh and by the way, some of our partners have used "flash cookies", which you can't delete. And maybe even "canvas fingerprints". But they pay us money or give us services, so we don't want to interfere.




HOW IS THIS INFORMATION USED?

Information that you provide to us will be used to process, fulfill, and deliver your requests for content and services. We may send you information about our products and services, unless you have indicated you do not wish to receive further information.

Information that is automatically collected is used to monitor usage patterns at NEJM.org and at our digital applications in order to help us improve our service offerings. We do not sell or rent your e-mail address to any third party. You may unsubscribe from our e-mail services at any time. Life is short. You may have a heart attack at any time, or get run over by a truck. For additional information on how to unsubscribe from our e-mail services, please refer to the How to Make Changes to Your Information section of this Privacy Policy.

We may report aggregate information about usage to third parties, including our service vendors and advertisers. These advertisers may include your competitors, so be careful. For additional information, please also see our Internet Advertising Policy. We may also disclose personal and demographic information about your use of NEJM.org and our digital applications to the countless companies and individuals we engage to perform functions on our behalf. Examples may include hosting our Web servers, analyzing data, and providing marketing assistance. These companies and individuals are obligated to maintain your personal information as confidential and may have access to your personal information only as necessary to perform their requested function on our behalf, which is usually to earn us more money, except as detailed in their respective privacy policies. So of course, these companies may sell the data collected in the course of your interaction with us.
Advertisers
We contract with third-party advertisers and their agents to post banner and other advertisement at our site and digital applications. These advertisements may link to Web sites not under our control. These third-party advertisers may use cookie technology or similar means i.e. Flash to measure the effectiveness of their ads or may otherwise collect personally identifying information from you when you leave our site or digital applications. We are not responsible or liable for any content, advertising, products or other materials offered from such advertisers and their agents. Transactions that occur between you and the third-party advertisers are strictly between you and the third party and are not our responsibility. You should review the privacy policy of any third-party advertiser and its agent, as their policies may differ from ours.
Advertisement Servers
In addition to advertising networks run by Google, which know everything about you already, We use a third-party ad server, CheckM8, to serve advertising at NEJM.org. Using an advertising network diminishes our ability to control what advertising is shown on the NEJM website. Instead, auctions are held between advertisers that want to show you ads. Complicated algorithms decide which ads you are most likely to click on and generate the most revenue for us. We're thinking of outsourcing our peer-review process for our article content to similar sorts of software agents, as it will save us a whole lot of money. Anyway, if you see ads for miracle drugs on our site, it's because we really need these advertising dollars to continue our charitable work of publicizing top quality medical research, not because these drugs have been validated by top quality medical research. CheckM8 does not collect any personally identifiable information regarding consumers who view or interact with CheckM8 advertisements. CheckM8 solely collects non-personally identifiable ad delivery and reporting data. For further information, see CheckM8’s privacy policy. Please note that the opt-out website we mentioned above doesn't cover CheckM8, And there's not a good way to opt out of CheckM8, so there. The Massachusetts Medical Society takes in about $25 million per year in advertising revenue, so we really don't want you to opt out of our targeted advertising.



WHAT SECURITY MEASURES ARE USED?

When you submit personal information via NEJM.org or our digital applications, your information is protected both online and offline with what we believe to be appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect. For information submitted via NEJM.org, we use the latest Secure Socket Layer (SSL) technology to encrypt your credit card and personal information. But other information is totally up for grabs.

USER-GENERATED CONTENT FORUMS
Any data or personal information that you submit to us as user-generated content becomes public and may be used by MMS in connection with NEJM.org, our digital applications, and other MMS publications in any and all media. For more information, see our User-Generated Content Guidelines. We'll have the right to publish your name and location worldwide forever if you do so, and we can sue you if you try to use a pseudonym.

OTHER INFORMATION

Do Not Track Signals
Like most web services, at this time we do not alter our behavior or change our services in response to do not track signals. In other words, our website tracks you, even if you use technical means to tell us you do not want us to track you.
Compliance with Legal Process
We may disclose personally identifying information if we are required to do so by law or we in good faith believe that such action is necessary to (1) comply with the law or legal process; (2) protect our rights and property; (3) protect against misuse or the unauthorized use of our Web site; or (4) protect the personal safety or property of our users or the public. So, for example, if you are involved in a divorce proceeding, we can help your spouse verify that you weren't staying late at your office reading up on the latest research like you said you were.

Children
NEJM.org is not intended for children under 13 years of age. We do not knowingly collect or store any personal information from children under 13. If we did not have this disclaimer, our lawyer would not let us do things we want to do. If you are under 13, we're really impressed, you should spend more time outside getting fresh air.

Changes to This Policy
This privacy policy may be periodically updated. We will post a notice that this policy has been amended by revising the “Last updated” date at the top of this page. Use of NEJM.org constitutes consent to any policy then in effect. So basically, what we say here is totally meaningless with respect to your ability to rely on it. Oh well.


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