Intealth Privacy Notice

Last Updated: November 19, 2024

Intealth and its divisions, ECFMG^® and FAIMER^® (hereinafter referred to collectively as “Intealth,” “we,” “us,” or “our”), are committed to protecting the privacy and security of your Data, including Personally Identifiable Information (“PII”) (collectively “Data”). This Privacy Notice explains how we collect, process, use, and disclose your Data (i) in connection with, and in support of, your use of Intealth websites and the web platforms Intealth uses to provide its programs and services (“Service Platforms”); (ii) in connection with your participation in Intealth-related educational and professional forums and collaborations; (iii) in support of our research endeavors; and/or (iv) in connection with an application for employment with Intealth.

Acceptance of Privacy Notice

Your use of the Intealth websites, web platforms, and Intealth programs and services signifies your understanding and acceptance of the terms of this Privacy Notice. Further, your continued use of the Intealth websites, Service Platforms, and/or Intealth programs and services following our posting amendments to the Privacy Notice signifies your acceptance of the Privacy Notice as amended.

Nature of Services Provided

Intealth provides programs and services to individuals and to organizations including certification, professional verification, credentialing, training, educational opportunities, and visa sponsorship. Intealth also collaborates in research, publications, and educational opportunities and makes employment opportunities available to individuals seeking to join our teams.

PII and Other Data We Collect

We collect PII and other Data either directly from you, through automatic technologies, and from third parties or publicly available sources, as follows:

Data Collected from You

• Users in Connection With and in Support of Our Programs and Services. We collect the following PII directly from individuals in order to provide our programs and services including some PII that may be considered sensitive PII under the applicable law in the jurisdiction where you reside. Depending on the Intealth program or service requested by the individual, the PII we collect may include but is not limited to an individual’s: name; image; address(es); e-mail address(es); birth date; birth country; passport and visa information; national identification numbers; United States Medical Licensing Examination^® (USMLE^®) number; medical license number, licensing jurisdiction, and licensing dates; gender; ethnicity; citizenship; birth certificate; marriage certificate; relevant information about any claimed disability; driver’s license information; financial information; and educational and work experience. For those Users seeking visa sponsorship, we collect PII of family members and dependents (including minors) also seeking sponsorship (under a J-2 visa), as follows: name, gender, date of birth, birth city, passport number, country(ies) of citizenship, country of legal personal residence, e-mail address, Student and Exchange Visitor Information System (SEVIS) number, and USMLE number (where applicable). Copies of passports, marriage certificates, and birth certificates must also be provided in support of sponsorship.
  
  In order to facilitate payment for our programs and services, we use third-party payment processors which directly collect your financial Data (for example, your bank account information or credit card details). The use of your financial Data is governed by the Privacy Policies of those processors, as applicable.
  
• Users Supporting Intealth or Participating in Educational and Professional Forums. PII is also collected from individuals working for organizations assisting Intealth to fulfill its services and/or organizations assisting individuals requesting Intealth programs or services, as well as donors, and individuals attending and/or presenting at Intealth educational and professional institutes and forums. The PII collected from such Users may include, but is not necessarily limited to: name, title, address(es), date of birth, birth country, e-mail address(es), phone numbers, and professional credentials.
  
• Users Seeking Employment Opportunities. Intealth generally collects the following PII from Users seeking professional opportunities with Intealth: name, address(es), e-mail address(es), phone numbers, gender, ethnicity, veteran status, disability status, education history, employment history, professional references, required background clearance data, and other job-related information.

In most instances, collection of this PII is required for Intealth to provide the requested opportunities and/or programs and services, or in other instances may be required by law. Non-provision of certain information may bar our ability to provide you with these opportunities and/or the requested programs and services.

Intealth may request that you participate in surveys and other evaluations in connection with your involvement with Intealth programs, services, and opportunities. When participating in such surveys and evaluations, Intealth may collect your PII or other Data. Your participation in such surveys and evaluations is strictly voluntary.

Data Collected Automatically

Intealth may collect certain Data about you automatically, using passive technologies. Such Data include technical information about browser type, areas of the site visited, date and time of access, and related Data in order to improve the overall quality of your on-line experience. These passive technologies include:

• Web Server Logs and IP Addresses. Internet Protocol (“IP”) addresses and mobile device identifiers are numbers that identify the computer or device that you use to access the Internet. Depending on the way in which you access the Internet and where you access the Internet, your IP address may always be the same or very similar each time you access the Internet, or may change each time you access the Internet. Intealth systems automatically collect IP addresses and mobile device identifiers to enable our servers to send you the web pages that you request via your Internet Service Provider. We will never use your IP address to specifically target your location, but we may use your IP address to target the general geographic area from which you are visiting our website where there is a business need and a lawful basis to do so. We may use your IP address for security purposes, administering and maintaining our websites, to support our applications and the services that you access, for calculating our website usage levels, for the prevention and investigation of fraudulent activities, and/or for other business practice improvement.
  
• Cookies. A “cookie” is a data file that a website sends to your browser, which then stores it on the device you are using to browse the website. Intealth uses different types of cookies to improve delivery of your online experience. Cookies do not personally identify Users, although they allow our web servers to differentiate one User from another. Cookies also allow us to transact business with you on the Internet. Strictly necessary cookies are cookies necessary to enable the basic features of Intealth websites to function and/or to provide a service that you have specifically requested. Performance and analytics cookies allow us to measure and improve our performance and provide us with information about how our websites are used and how visitors move around our website. One specific type of performance and analytics cookie we use is Google Analytics. We use Google Analytics to assist us with understanding how Users interact with and use our website, which helps us improve our websites, applications, and offerings. Please refer to the Google Analytics Terms of Use and Privacy Policy for information regarding how Google may use and share the information collected by Google Analytics. You can opt out of being tracked by Google Analytics by visiting http://tools.google.com/dlpage/gaoptout. Functional cookies allow us to analyze your use of our websites to evaluate and improve our performance and to enhance and personalize your User experience by remembering User login details and other preferences. Non-essential cookies allow Intealth to keep track of Users who return to our website and for Users to share certain pages with social networks. Intealth uses all types of cookies on its websites and mobile applications. You can set your browser to refuse cookies except for strictly necessary cookies. However, disabling cookies may impact your ability to navigate all Intealth websites’ functionality.
  
• Web Beacons. Intealth web pages may use web beacons in conjunction with cookies to compile aggregate statistics about website usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) commonly used to track User traffic patterns from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of our websites. Some web beacons may be unusable if you refuse their associated cookies.
  
• “Do-Not-Track” Signals. Some web browsers transmit "do-not-track" signals to our websites. Although web browsers may incorporate and activate this functionality in different ways, Intealth currently does not respond to these signals.

Data Collected from Third Parties

We may also use or supplement the Data we have about you with information provided by other sources, such as the USMLE program, NBME, the National Resident Matching Program^® (NRMP^®), American Medical Association (AMA), Federation of State Medical Boards (FSMB), Association of American Medical Colleges (AAMC), Accreditation Council for Graduate Medical Education (ACGME), the Department of State (DoS), the Department of Homeland Security (DHS), medical schools, graduate medical education and training programs, current and former employers, licensing and regulatory authorities, professional organizations, and other organizations with which we collaborate in the provision of our programs and services. Where such information is received, Intealth will only use that Data in a manner consistent with the purposes for which it was provided to us.

How We Use Personal Information

Intealth may use your PII to:

• establish the applicable User account in our systems (e.g., as an applicant for our programs and services or as an applicant for job opportunities);
• process and fulfill requests for Intealth programs and services and employment opportunities;
• deliver newsletters and promotional materials that support Intealth’s mission and mandate (“promotional e-mails”);
• provide customer service in connection with our programs and services and employment opportunities;
• respond to legitimate business inquiries;
• support professional work and educational opportunities;
• confirm your identity;
• perform analyses and other internal assessments to administer our business and to improve the quality of Intealth business and service offerings;
• provide information and donor opportunities to support Intealth’s work and mission;
• facilitate engagement by alumni from our educational programs, including but not limited to alumni of our FAIMER Regional Institutes;
• address legal and regulatory inquiries made in the interest of serving the public;
• maintain permanent records of Users of Intealth programs and services as necessary to prevent fraud and serve the interests of the public;
• complete regulatory audits and compliance investigations;
• respond to inquiries from governmental and regulatory authorities;
• conduct statistical research and analysis that support our programs and services, mission, and other business interests;
• monitor for fraud and security threats; and/or
• fulfill any other purpose for which it was collected or provided to us, as stated at the time of collection, or as otherwise implied based on the context of the collection.

Intealth uses e-mail addresses collected for administrative and promotional purposes. Administrative e-mails are necessary to keep Users informed about critical aspects of programs and services. These must be received by Users in a timely manner. Therefore, the option to unsubscribe from administrative e-mails and alerts is not available to Users. However, if you wish to opt-out of promotional e-mails, please follow the unsubscribe instructions provided within individual newsletters and/or promotional e-mails.

Intealth reserves the right to aggregate PII provided by Users for statistical analysis and on-going research in accordance with our mission. To this end, Intealth compiles PII into aggregated data groups. Intealth may de-identify or pseudonymize the PII for statistically accurate data analysis without risking exposure of PII. Such data groups may then be shared with business partners, service providers, and/or vendors of Intealth or published on our website, in academic journals, or in presentations.

Basis for Processing PII

Applicable law in certain countries, including but not limited to countries in the European Economic Area, require that we collect and process PII only where we have an identified lawful basis to do so under applicable law. Depending on the program and service and/or opportunity provided and/or the processing activity involved, we collect and process your PII only where we have one of the following lawful bases to do so:

• You Provide Your Consent: You provide us with consent to collect and process your PII for a specific purpose;
  
• We Must Do So to Perform Our Contract with You: We process your PII to fulfill your request to provide programs and services or other opportunities;
  
• We Have a Legitimate Interest: We have a legitimate interest to process your PII that is not overridden by your interests, fundamental rights, or freedoms; and/or
  
• We Must Do So to Comply with Legal Obligations: We process your PII if it is necessary for us to comply with our legal obligations.

Where we process “special” or “sensitive” categories of PII, as defined by the General Data Protection Regulation, we do so only: (i) where you have given us your explicit consent to carry out such processing; or (ii) as otherwise permitted by law.

If you have questions or concerns about the lawful basis for which we collect and process your PII, please contact privacy@intealth.org.

Personal Information of Minors

Except as noted below, minors (i.e., persons under 18 years of age) are not eligible for participation in Intealth programs or services, and/or employment opportunities. Therefore, Intealth does not intentionally collect PII from minors. If Intealth identifies that a minor has submitted PII, we will take all reasonable steps necessary to delete the PII from our databases and not use or retain it for any purpose. Further, if you believe a minor has submitted PII to Intealth, please contact us at privacy@intealth.org.

Intealth provides visa sponsorship for authorized foreign national physicians and unmarried, minor dependents of such authorized foreign national physicians under the age of 21. Under such sponsorship and to meet J-1/J-2 visa requirements, Intealth must collect PII of minor dependents for U.S. government agencies; however, such information is collected from the authorized foreign national physician, not the minor dependent.

Data Retention and Destruction

Intealth retains your Data for as long as necessary to fulfill the purposes we collected it for, for the duration of our business relationship with you, and in accordance with our Data Retention and Destruction Policy. Intealth may maintain a lawful basis for retaining certain PII indefinitely, for example, where Intealth services are benefiting the public interest in the area of public health, such as through verification of professional credentials. PII deleted from our active database in accordance with our Policy may be retained in de-identified format for research, data aggregation, and statistical purposes.

How We Disclose and Share PII

We may disclose and share your PII with third parties, as follows:

• organizations assisting Intealth to fulfill its programs and services including but not limited to verifying institutions (such as educational institutions, medical schools and post-graduate training institutions), identity verification providers, translation providers, test providers, USMLE, the ACGME, NBME, the NRMP, and FSMB;
• other organization(s) or individual(s) in order to facilitate on-going services;
• U.S. or international governmental agencies and other organizations, including medical and other regulatory authorities;
• peer health professions education organizations and other non-profit organizations involved in health professions education;
• any individual, organization, or government or regulatory authority that a User specifies should receive the information or authorizes to receive such information;
• IT and systems administration services (such as cloud hosting services and e-mail or mail solutions);
• Internet Service Providers;
• services that assist in processing employment applications;
• personnel administration services;
• other organization(s) or individual(s) that support Intealth programs and services; and
• professional advisors (such as lawyers, bankers, auditors, insurers, and investigative firms).

Where such disclosures are made, they are governed by agreements (including Intealth’s Terms and Conditions, confidentiality agreements, data sharing agreements, and data processing agreements) that require protection of your PII and that only permit use of your PII in a manner consistent with this Privacy Notice.

There may be circumstances where you would like information in your Intealth records to be disclosed to a third party, such as a friend or family member. We will not disclose your information to such individuals unless you have authorized us to do so.

To Protect Our Legal Rights and Interests or Where Required by Law

Intealth may disclose PII to respond to valid subpoenas, court orders, legal processes, medical or other regulatory authority inquiries and investigations, or other governmental inquiries and investigations; to exercise our own legal rights to defend against legal claims/suits; to investigate, prevent, or take action against illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person or the general public; or as otherwise required by law.

In the Event of a Change in Corporate Status

In the event that Intealth is involved in a merger, acquisition, sale of assets, bankruptcy, and/or reorganization, your Data may be sold or transferred as part of that transaction. Any Agreement with such new entity or receiver will include appropriate privacy protections.

No Disclosures for Direct Marketing and Advertising

Intealth does not disclose, sell, rent, license, grant access to, or trade PII with third parties for direct marketing.

Cross-Border Transfers of PII

All PII collected and/or received by Intealth is stored and maintained on servers in the United States, where national and state privacy laws may not afford the same level of protection as where you reside. Further, fulfillment of many of our programs and services require the cross-border transfer of PII from Intealth to other countries, for example, to verify an individual’s credentials and/or to provide information to international medical regulatory authorities; similarly, the national and state privacy laws in those countries may not afford the same level of protection as where you reside. Intealth transfers Data across borders only where we have your consent to do so, when such processing is necessary to perform our contractual obligations to you (for example, to verify a credential), or where we have ensured an appropriate level of protection of your Data (e.g., to a jurisdiction that has received an adequacy decision or pursuant to standard contractual clauses).

Data Privacy and Security

Intealth has implemented reasonable administrative, technical, and organizational safeguards to protect against foreseeable risks of unauthorized access, use, disclosure, destruction, or modification of PII and its information systems.

Please note, however, that despite the best efforts of Intealth, the confidentiality and security of information and Data transmitted to/from Intealth cannot be guaranteed as completely safe from intrusion.

Please do your part to protect the personal information that you share with Intealth. Keep your username, password, or other authentication information secure and limit the dissemination of your account information to third parties to those circumstances where dissemination is absolutely necessary. If you believe that your username, password, or other information associated with your Intealth account has been compromised, please contact us at privacy@intealth.org.

Data Protection Rights

Depending on where you reside, your local privacy laws, including but not limited to the European Union’s General Data Protection Regulation, may provide you with certain rights with respect to your PII, as follows:

Access, Review, and Rectification

Some Users may have the right to access and review their PII collected and maintained by Intealth, with limited restrictions. Users can submit a formal request for access and review by contacting privacy@intealth.org. All such requests will be tracked and responded to in a timely manner, not to exceed 30 calendar days from the date of the request.

Erasure and Restricting Processing

Under certain circumstances, some Users may have the right to request that their PII be deleted or removed from Intealth’s systems, or that Intealth restrict the processing of their PII. These rights are not absolute. Many of Intealth’s services are intended to prevent fraud and to serve the public interest in the area of public health. As a provider of these services, Intealth may have a lawful basis to refuse User requests for erasure of PII and/or to refuse User requests to restrict or object to processing PII.

Filing Complaints

Applicable Users have the right to make a complaint to Intealth by contacting privacy@intealth.org and/or to request that Intealth direct the User to relevant supervisory authorities to file a formal complaint.

Privacy Notices of Unaffiliated Third-Party Websites

This Privacy Notice applies only to Intealth and Intealth’s privacy practices. The Intealth website, Intealth service platforms or applications, newsletters, blogs, social media accounts, and other Intealth publications or releases may include links to unaffiliated third-party websites and applications whose privacy practices may be different than ours. Users clicking on these links should be aware that they are leaving the Intealth website and/or application and are accessing the unaffiliated third-party website. Users should review the Privacy Notice of the unaffiliated third-party website before engaging their services or products.

Changes to This Privacy Notice

This Privacy Notice may be amended from time to time as new features, programs, and services are made available, as laws and regulations change, or as otherwise necessary and appropriate. Notice about amendments to the Privacy Notice will be communicated by administrative e-mails, posted online, or by other appropriate methods. User access and/or on-going use of the Intealth websites and/or other Intealth programs and services after such amendments signifies acceptance of the Privacy Notice, as amended. The most current version of the Privacy Notice is available at www.intealth.org and includes the date the Privacy Notice was last updated.

How to Contact Us

If you have questions about the terms of this Privacy Notice or if you need more information, please contact Intealth at privacy@intealth.org.

Intealth
Attn: Privacy Office
3624 Market Street
Philadelphia, PA 19104 USA
+1 (215) 386-5900