Continuing medical education (CME) providers must be cognizant of privacy issues regarding their physician clients. The CME Coalition, which represents a wide variety of CME companies, has developed with the help of the law firm Arnold and Porter a model online privacy policy for continuing medical education providers. Click here for the template, which includes the information necessary for providers to tailor the document to their own policies.
CME Coalition’s website notes that the increased use and visibility of the suggested privacy policy “can increase public awareness and confidence in the systems in place to protect inappropriate use or transfer of physician data.”
“The CME Coalition and its members are committed to ensuring that continuing medical education and accredited providers meet the highest ethical standards in all regards,” stated CME Coalition Senior Advisor Andrew Rosenberg, “and this includes permitting only the proper use of physician data.”
The model policy will help ensure that CME provider entities – both within and outside of the CME Coalition – have “best practices” in place with regard to their treatment of collected learner data.
The Coalition’s suggested privacy policy template is available for use by its members and the public at-large, but comes with a warning:
“We’ve designed this to be for a company named ‘CME Provider’ and obviously the references to that name, as well as its website name, contact information, etc., will need to be replaced by any organization that uses the template. At least as important, the template is only useful insofar as it accurately describes the functions and practices of the website to which it pertains — any statements in a website privacy policy that do not accurately reflect actual practices are the basis for claims of deception and misrepresentation. So great caution should be used…”
The CME Coalition has provided a number of excellent services for CME providers over the last year. Their comprehensive Sunshine Compliance Guidefor CME events provides much needed clarity on the Sunshine Act’s tricky CME exemption for medical education providers.