ECFMG|FAIMER Privacy Notice
ECFMG®|FAIMER® is committed to protecting the privacy and security of your personal information. ECFMG|FAIMER refers to: Educational Commission for Foreign Medical Graduates (“ECFMG”), Foundation for Advancement of International Medical Education and Research (“FAIMER”), and Clinical Skills Evaluation Collaboration (“CSEC”) (hereinafter referred to collectively as “ECFMG|FAIMER,” “we,” “us,” “our”). The ECFMG|FAIMER Privacy Notice (“Privacy Notice”) explains how we collect, use, and disclose personal information for (i) our programs and services, (ii) administration of programs and services, (iii) research endeavors, and (iv) employment opportunities we offer and make available to website and mobile application users (“Users”).
Acceptance of Privacy Notice
Your use of the ECFMG|FAIMER websites, programs and services, web-based applications, and related administrative processes signifies your understanding and acceptance of the terms of this Privacy Notice. If you do not agree to the terms of this Privacy Notice, please do not submit your personal information or any personal information you are responsible for to ECFMG|FAIMER or use its websites and mobile applications. Further, your continued use of ECFMG|FAIMER programs and services, websites, and mobile applications following our posting amendments to the Privacy Notice signifies your acceptance of the Privacy Notice as amended.
Nature of Services Provided
ECFMG|FAIMER provides services and products directly to individuals and to organizations and collaborates in research, publications, and educational opportunities. Services may include verification, credentialing, training, and other educational opportunities. ECFMG|FAIMER also makes employment opportunities available to Users seeking to join our teams. Therefore, ECFMG|FAIMER collects a broad base of Personally Identifiable Information (PII) for these purposes consistent with its mission and goals.
Personal Information We Collect
PII is provided directly by individuals accessing the ECFMG|FAIMER services and products. ECFMG|FAIMER serves Users seeking professional verification services, as well as work and educational opportunities that may require visa sponsorship and/or temporary residence in the United States. Therefore, ECFMG|FAIMER collects a broad base of PII for these purposes, including some sensitive information as defined by domestic and international data privacy regulations. PII collected includes but is not limited to: individual’s name, image, home address, e-mail address, birth date, birth country, passport and visa information, national identification numbers, driver’s license information, financial information, and educational and work experience. Sensitive information collected includes gender, ethnicity, citizenship, birth country, and relevant information about any claimed disability. We collect limited and necessary PII of family members and dependents, including minors, from Users seeking visa sponsorship.
PII is also collected from individuals working for organizations assisting ECFMG|FAIMER to fulfill its services as well as from those attending and/or presenting at educational and professional forums. All PII will be maintained in accordance with the terms of this Privacy Notice. PII collected from individuals working for organizations assisting ECFMG|FAIMER includes but is not limited to: names, titles, address, e-mail addresses, phone numbers, and other relevant information. PII from attendees and presenters includes but is not limited to: names, address, work address, e-mail addresses, phone numbers, professional credentials, and relevant financial information.
For those Users seeking employment opportunities, ECFMG|FAIMER generally collects: names, e-mail address, postal address, telephone number, employment history, references, required background clearance data, and job-related information. Applicants are required to respond to all questions on our employment application forms. Employment data will be processed and retained in accordance with the HR policies and procedures of ECFMG|FAIMER.
How We Use Personal Information
ECFMG|FAIMER uses PII for the specific and limited purposes outlined in our websites and in materials and contracts, including:
- providing ECFMG|FAIMER programs and services;
- providing employment opportunities;
- supporting professional work and educational opportunities;
- confirming the officials who verify credentials at verifying organizations;
- performing analyses and other internal processes to improve the quality of ECFMG|FAIMER business and service offerings;
- providing information and donor opportunities to support ECFMG|FAIMER work and mission;
- addressing legal and regulatory inquiries made in the interests of serving the public;
- maintaining permanent records of Users of ECFMG services and programs as necessary to prevent fraud and serve the interests of the public;
- completing regulatory audits and compliance investigations;
- responding to inquiries from governmental and regulatory authorities;
- conducting statistical research and analysis; and
- being responsive to other legitimate business inquiries.
ECFMG|FAIMER uses e-mail addresses collected for administrative and promotional purposes.
Administrative notices and alerts necessary to keep Users informed about critical aspects of programs and services are sent by e-mail. 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.
Various ECFMG|FAIMER programs and services offer newsletters and promotional materials and solicit donations to support its mission and mandate. ECFMG|FAIMER uses e-mail addresses collected for such promotional purposes. If you wish to opt-out of our newsletter and/or promotional e-mails, please follow the unsubscribe instructions provided with individual newsletters and/or promotional e-mails.
ECFMG|FAIMER reserves the right to aggregate data provided by Users for statistical analysis and on-going research in accordance with our mission. To this end, ECFMG|FAIMER compiles PII into aggregated data groups. ECFMG|FAIMER 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 the affiliates, business partners, service providers, and/or vendors of ECFMG|FAIMER.
Personal Information of Minors
Except as noted below, minors (i.e., persons under 18 years of age) are not eligible for participation in ECFMG|FAIMER programs, services, and/or employment opportunities. Therefore, ECFMG|FAIMER does not intentionally collect PII from minors. If ECFMG|FAIMER 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.
Please note that under limited circumstances, ECFMG|FAIMER provides visa sponsorship for authorized foreign national physicians and unmarried, minor dependents under the age of 21. Under such sponsorship and to meet J-1/J-2 visa requirements, ECFMG|FAIMER must collect PII of minor dependents for U.S. government agencies. Parental consent is required at the time of collection of the minors’ PII.
Data Retention and Destruction
ECFMG|FAIMER retains PII in accordance with our Data Retention and Destruction Policy. Where ECFMG|FAIMER services are benefiting a public interest, for example through verification of professional qualifications, ECFMG|FAIMER maintains a legitimate basis for retaining PII for an unlimited time period. 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.
Information We Collect through Passive Technologies
ECFMG|FAIMER websites and mobile applications collect certain information automatically, including 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. ECFMG|FAIMER 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 also use this information to conduct systems analysis and performance reviews necessary to administer and maintain our websites. We use other information provided by your browser to enable support for our applications and the services that you access.
Stateful Applications and Data. Stateful applications track data automatically from your computer or mobile device. Stateful applications, such as cookies, web beacons, etags, and similar functionality, are placed automatically on your web browser when you access ECFMG|FAIMER websites and mobile applications and grant us persistent storage of this data as you navigate our websites. Cookies do not personally identify Users, although they allow ECFMG|FAIMER web servers to differentiate one User from another. Cookies also allow us to transact business with you on the Internet.
Web Beacons. ECFMG|FAIMER 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, ECFMG|FAIMER currently does not respond to these signals.
How We Disclose Personal Information
PII is provided directly by individual Users with notice of and their consent to ECFMG|FAIMER defined uses and disclosures of the PII. ECFMG|FAIMER discloses limited and necessary PII about User applicants to its programs and services to:
- organizations that a User specifies should receive the information;
- organizations assisting ECFMG|FAIMER to fulfill its services;
- other organization(s) or individual(s) in order to facilitate on-going services, conduct related research and/or analyses, or support other programs;
- U.S. or international governmental agencies and other organizations, including regulatory authorities, with a legitimate legal basis for access to the PII and related information; and
- address other legal purposes in support of ECFMG|FAIMER services, mission, and mandate.
Affiliated Third Parties under Contractual Relationships with ECFMG|FAIMER. ECFMG|FAIMER may grant restricted and limited access to its systems maintaining PII under confidentiality agreements, data sharing agreements, and/or data processing agreements with affiliated third parties that work with, support, or provide products and services to or on behalf of ECFMG|FAIMER. Such affiliated third parties include but are not limited to those providing:
- e-mail or mail solutions;
- payment processing solutions (e.g., PayPal, TeleCheck);
- external and cloud hosting services;
- analysis of usage of ECFMG|FAIMER websites;
- support and maintenance services for ECFMG|FAIMER websites and mobile applications;
- services to assist us in processing employment applications and HR services;
- services to assist with credentialing and visa sponsorship operations, including but not limited to identity verification, translation services, and investigative firms; and
- program and other surveys (e.g., SurveyMonkey).
Such affiliated third parties have no independent right to maintain, share, or further disclose PII in the systems and/or applications.
Legal and Regulatory Authorities. ECFMG|FAIMER may provide restricted and limited access to our systems maintaining PII to our legal, regulatory, audit, or other professional advisors to assist with legitimate business interests. However, such affiliated third parties have no independent right to maintain, share, or further disclose PII in the systems and/or applications.
Special Circumstances. ECFMG|FAIMER may provide restricted and limited access to PII in our systems to respond to valid subpoenas, court orders, legal processes, regulatory authority investigations, or governmental inquiries; to exercise 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.
Change in Corporate Status. In the event that ECFMG|FAIMER is involved in a merger, acquisition, sale of assets, bankruptcy, and/or reorganization, your PII may be sold or transferred as part of that transaction. Accordingly, any new entity or receiver will be bound by this Privacy Notice after the sale, transfer, or change in legal status.
Marketing and Advertising. At this time, ECFMG|FAIMER does not disclose, sell, rent, license, grant access to, or trade PII with unaffiliated third parties for direct marketing. If ECFMG|FAIMER begins to engage in these activities, we will post this change as an amendment to our Privacy Notice.
Cross-Border Transfers of PII
All PII compiled by ECFMG|FAIMER is stored in or on servers in the United States. Transmission of PII of website and mobile application Users and PII in paper format originating from outside the United States to ECFMG|FAIMER constitute a cross-border data transfer. Notice to Users about cross-border data transfers is required by international data privacy regulations to be included in Privacy Notices and contractual agreements. Notice of cross-border data transfers is hereby provided and reinforced in contractual documents. Continued use of ECFMG|FAIMER programs and services signifies User agreement to on-going cross-border data transfers.
Data Privacy and Security
ECFMG|FAIMER implements reasonable administrative, technical, and physical 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 ECFMG|FAIMER, the confidentiality of information and data transmitted to/from ECFMG|FAIMER cannot be guaranteed.
Your Data Protection Rights
Access and Review. Users have the right to access and review their PII collected and maintained by ECFMG|FAIMER, with limited restrictions. Most applications provide password-protected portals to authorized Users for review, correction, and updating of their PII. For restricted files, Users can request access and review by contacting privacy@ECFMG.org or privacy@FAIMER.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 Access. Some ECFMG|FAIMER services are intended to prevent fraud and to serve the public interests. As a provider of these services, ECFMG|FAIMER has a fiduciary duty to maintain accurate files and preserve data identified about Users through its processes. Accordingly, ECFMG|FAIMER has a legitimate basis to refuse User requests for erasure of PII identified through these services and/or to refuse User requests to restrict or object to processing PII identified that ECFMG|FAIMER deems relevant to User’s professional qualifications and credentials. Users have the right to appeal refusals by contacting privacy@ECFMG.org or privacy@FAIMER.org, but ECFMG|FAIMER reserves the right to make the final decision about the information identified and the requests.
Filing Complaints. Users have the right to make a complaint to ECFMG|FAIMER by contacting privacy@ECFMG.org or privacy@FAIMER.org, and/or to request that ECFMG|FAIMER 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 ECFMG|FAIMER and its information collection and use practices. Users may encounter links to unaffiliated third-party websites, ads, and materials available through the ECFMG|FAIMER websites. ECFMG|FAIMER is not responsible for these unaffiliated third-party websites, ads, and materials. Users clicking on these links should be aware that they are leaving the ECFMG|FAIMER websites 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, products, and services are made available and/or as laws and regulations change. Notice about amendments to the Privacy Notice will be communicated by administrative e-mails, posted on-line, or by other appropriate methods. User access and/or on-going use of ECFMG|FAIMER programs, services, websites, and/or mobile applications after such amendments signifies acceptance of the Privacy Notice, as amended. The most current version of the Privacy Notice is available at www.ECFMG.org or www.FAIMER.org and will include the effective date of the Privacy Notice.
How to Contact Us
Attn: Privacy Office
3624 Market Street
Philadelphia PA 19104 USA