Purpose

The Cycle of Engagement and its websites, which includes the Cycle of Engagement (“COE”) website, the Well Visit Planner (“WVP”) and Promoting Healthy Development Survey (“PHDS”) Use Portals, and CARE_PATH for Kids (“CPK”) website, are developed and is maintained by the Center for the Advancement of Innovative Health Practices doing business as Child and Adolescent Health Measurement Initiative (“CAHMI” or “we” or “us”). This Privacy Notice describes how we collect, use and protect the information of Providers, practices, and organizations (collectively “Providers” or “you”) who maintain a COE account and their families.

How your information is protected and secured

Data Minimization and Retention:

CAHMI minimizes the amount of personally identifiable information (PII) that it collects. All data is secured in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA). PII is encrypted and stored on CAHMI’s HIPAA compliant server and retained no longer than necessary for the purposes for which it was collected, or which it is required by law, at which time it will securely deleted or destroyed.

Data Security of Provider Data

The information gathered from you is confidential. The email address that you use for registering an account or provide within either the WVP or PHDS Use Portal will not be sold or shared with any third parties, nor will your email address be sold or used for purposes other than for us to share educational resources or sending updates about the COE. If you no longer wish to receive resources or updates, you can unsubscribe at any time.

Data Security of Family Data

The information gathered about the users invited to use your COE Family Websites is confidential. CAHMI requires the collection of a minimum necessary amount of personally identifiable information (PII) to associate a Clinical Summary and/or Well Visit Guide to an individual child. A security management risk analysis, conducted in accordance with 45 CFR § 164.308(a)(ii)(A) has determined that the information required by CAHMI’s COE tools represents a minimal risk to a loss of privacy and/or a breach of confidentiality. Providers who have an account with the COE and have enabled use of the WVP Family Website can request completed Well Visit Guides and Clinical Summaries with minimal identifiers to be stored on their WVP Use Portal.

Depending on Well Visit Planner customization choices, Providers may request and/or require additional PII from families. In order for CAHMI to collect this additional PII, families must consent to its collection and Providers must acknowledge and accept responsibility for the security of all Well Visit Guides, Clinical Summaries and data files accessed, downloaded, printed, or shared through the Provider WVP Use Portal.

Providers who have an account with the COE and have enabled use of the PHDS Use Portal can generate summary reports of aggregated findings based on parents’ responses on the Online PHDS parent tool, specific to their practice or organization. Providers will not know what the parents’ individual responses are nor be able to identify who completed the Online PHDS.

For additional information on data security of information collected on any Well Visit Planner Family and Online Promoting Healthy Development Survey Websites, please contact the CAHMI at info@cycleofengagement.org.

Managing Data

CAHMI takes the responsibility of ethical data stewardship seriously. We are committed to giving you control and genuine choice about how your data is used. We strive to be transparent about our data usage and provide you with the information you need to make informed choices.

CAHMI reserves the right to use deidentified, aggregate data provided by users of the COE for research purposes related to child health and quality of health care services. CAHMI may also use feedback and usage data to detect trends and drive improvements resulting in better performance and enhancements. When you choose to share feedback with the CAHMI on any of the COE tools and websites, we use your data to understand what COE tool users want and guide our development efforts.

You are solely responsible for all activity on or related to your account, your customized content, and for the security of your computer, mobile device, and any other device that you use to access the website. You should not reveal your account password to other users or permit others to access your account. You shall promptly notify us of any changes to your account information or if such information has been disclosed to a third party in violation of this Privacy Notice. If there is a risk of your account being improperly used by a third party, you shall promptly take all reasonable measures to limit such use, including, without limitation by changing your password and notifying the CAHMI. Under no circumstances shall CAHMI be liable to you for any loss you incur, from your loss of any account information, unauthorized access or use of your account and/or from harmful or malicious code.

In no event shall CAHMI or any of its directors, officers, employees, agents, affiliates, or content or service providers be liable for any indirect, special, incidental, consequential, exemplary or punitive damages arising from or directly or indirectly related to the use of, or the inability to use, the website or the content, materials and functions related thereto, including, without limitation, loss of revenue, or anticipated profits or lost business or lost sales, even if such entity has been advised of the possibility of such damages.

How to contact CAHMI with any questions

If you have any questions about CAHMI, the Cycle of Engagement, Well-Visit Planner, Online Promoting Healthy Development Survey or any other tools and features, you can contact us online at info@cycleofengagement.org.