Updated as of December 12, 2022
We are committed to the care and improvement of human life. Part of that commitment includes protecting your Personal Information (defined below). We maintain information confidentiality and comply with applicable regulatory requirements.
This privacy policy (“Privacy Policy”) covers our online privacy practices with respect to use and/or disclosure of information we may collect from you when you access or use our website (“Website”), Portals (as defined below), and any other websites or applications we may provide that link to this Privacy Policy (collectively, our “Services”). The Services are provided by the Website owner identified on the Website homepage (“we,” “us,” or “our”). This Privacy Policy does not apply to information collected through other means, such as by telephone or in person or by other third-parties that are not part of our Services. Please review our privacy practices and email us if you have questions.
Our Website may include pages that permit you the opportunity to provide us with Personal Information about yourself. As used in this Privacy Policy, “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual as defined by applicable state laws as noted below.
We collect certain information, including Personal Information, from and about our Website users in three ways:
We and our service providers collect Personal Information through online forms to provide certain features of the Services to you. For example, if applying for a job through the Website, we may request you to fill out a form with information such as your name, e-mail address, phone number, and work experience. If you do not provide the information required to submit the forms, we may not be able to provide you with related features and services.
In some cases, you may have the opportunity to enter into our secure forms any content that you choose. You are responsible for such content and we reserve the right to use such content as part of our Services.
When you access or use our Services, we may track information to administer our Services and analyze its usage. Examples of information we may track include, without limitation:
We use this information to analyze and improve our Services, monitor traffic and usage patterns for information security purposes, and to help make our Services more useful.
A “cookie” is a small text file that may be transferred to your computer’s hard drive to personalize our services for you and collect information regarding usage of our Services. Each computer is assigned a different cookie that contains a random, unique identifier. Our Services may use two different types of cookies: a “session” cookie, which is required to track a user session, for example, and which expires shortly after the session ends, and a “persistent” cookie, used to track unique visits to the Portal (defined below), as well as how the user arrived at the Portal (for example, through an email link or from a referral link), and the type of user (patient, provider, consumer, etc.). So that users are not counted twice, this cookie can “persist” anywhere from six months to two years.
Your browser software can be set to warn you of cookies or reject all cookies. Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookie, this may disable some of the functionality of our Services and you may not be able to use certain services.
Cookies, to the best of our knowledge, cannot be used to run programs or deliver viruses to your computer. One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a website, a cookie helps the website to recall your specific information on subsequent visits. This simplifies the process of delivering relevant content and eases website navigation by providing and saving your preferences and login information as well as providing personalized functionality.
We use Google Analytics, a web analytics service provided by Google LLC, on our Site to help us analyze the traffic and user activity on our Site. Please see Google’s Privacy and Terms for more information on how Google Analytics processes Personal Information. By using a browser plugin provided by Google, you can opt-out of Google Analytics for the web.
We may display content from third-party platforms or services that allow you to view their hosted content directly from the pages of our Site, and interact with them. For example, we use YouTube, a video sharing and social media platform provided by Google LLC, to embed video content on our Site. Google’s Privacy Policy explains how YouTube/Google treat your personal data and protect your privacy when you provide your personal data in connection with your access and use of their services.
Some of features of our Services (such as social media widgets that allow you to share content) may use cookies or other methods to gather information regarding your use of the Services, and may combine the information in these cookies with any of Personal Information about you that they may have. The use of such information by a third-party depends on the privacy policy of that third-party.
A “web beacon,” “clear GIF,” “web bug,” or “pixel tag” is a tiny graphic file with a unique identifier that is similar in function to a cookie, but would allow us to count the number of users that have visited certain pages or screens of our websites, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which may be stored on your computer’s hard drive, web beacons are typically embedded invisibly on pages or screens. We may use web beacons in providing the Services.
We reserve the right to share aggregated site statistics monitored by cookies and web beacons with our affiliates and partner companies. We treat the information of everyone who comes to our Services in accordance with this Privacy Policy. We do not honor Do Not Track (DNT) requests. To determine whether any of our third-party service providers (see the How We Disclose Personal Information section below) honor DNT requests, please read their respective privacy policies.
We do not collect precise information (e.g., GPS data; latitude and longitude) concerning the location from which you access the Services, but we collect information on your region or postal code to help us gather information useful for improving the relevance of our content and securing our Services.
We may allow third-party advertising companies to serve ads when you access or use our Services. These companies use non-personally identifiable information regarding your access and use of our Services and other websites, such as pages viewed, date and time of your visit, and number of times you have viewed an ad (but not your name, address, or other personal information), to serve ads to you on our Services and other websites that may be of interest to you. In the course of serving advertisements to our Services, our third-party advertiser may place or recognize a unique cookie on your browser. In addition, we or other third-party advertiser, may use web beacons to help manage our online advertising. This allows us or a third-party advertiser to learn which banner ads bring users to our Services.
We use Google Ads, the Google Marketing Platform and related marketing and advertising services provided by Google, LLC in connection with our Site and general corporate advertising and marketing operations for purposes of, among other things, online advertising, which includes remarketing, re-engagement, or similar audience and advertising and marketing features. You can control the information Google uses to show you ads by changing your Google Ad Personalization Settings. Additionally, you can learn more about Google ad personalization and additional controls available to you by visiting Google Ad Help.
We use Twitter Ads, an advertising and analytics service provided by Twitter, Inc., in connection with our Site to run advertising and marketing campaigns on Twitter. You can opt-out of Twitter’s interest-based advertising through an applicable opt-out mechanism specified by Twitter.
We use Facebook Ads and related services provided by Facebook, Inc. in connection with our Site to run advertising and marketing campaigns on Facebook. Facebook’s Cookie Policy explains how Facebook uses data to show you ads and how you can control usage.
You can learn about additional steps that you may take to opt-out of interest-based advertising when browsing the web by visiting National Advertising Initiative (NAI) Consumer Opt-Out.
As a Service to its customers, we may also provide Portals to offer some customers secure, private access to their own records at our facilities, as well as certain internet-based services which may include, among other things, assistance in finding a doctor, assistance in scheduling appointments, the ability to register for classes and pre-register for procedures, the ability to make payment for medical services rendered, and access to health and patient education materials and secure messaging (“Portal”).
The Portal can provide you with access to some of your medical records. When you seek access to those records on the Portal, we need to confirm your identity, so we ask you for information such as your name and email or physical address and other information such as your date of birth (which we may also use to make sure you are eligible to use the Portal in accordance with the Terms) and the answers to “secret questions” to which only you know the answers. This information may be used to help administer your user account and in managing your account. We may need to ask you for the information again when you sign in from a new device.
We may ask for information about your location and medical needs to assist with finding a physician, and may collect and pass on information (which may include, where relevant, health information such as your patient history) to assist you in scheduling appointments, pre-registering for procedures, and registering for classes.
If you submit or we collect Personal Information through our Services, then such Personal Information may be used in the following ways: (i) to provide, analyze, administer, and improve our Services; (ii) to contact you in connection with our Services and appointments, events or offerings that you may have registered for; (iii) to identify and authenticate your access to the parts of our Portal or other password-protected Services that you are authorized to access; (iv) to send you surveys; (v) for recruiting and human resources administration purposes; (vi) to protect our rights or our property and to ensure the technical functionality and security of our Services; and (vii) as required to meet our legal and regulatory obligations.
If you have questions about or need further information concerning the legal basis on which we collect and use your information please contact us.
If you are a resident of the European Economic Area, our legal basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the context in which we collect it. We collect information from you:
If you are a resident of the European Economic Area and you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact our appointed EU representative, the DPO Centre.
We do not sell, lease, rent or otherwise disclose the Personal Information collected from our Site to third-parties unless otherwise stated below or with your consent.
In addition to the uses and disclosures of information outlined above, if you use the Portal, your information may also be used and disclosed as follows:
No website can guarantee security, but we maintain industry accepted physical, electronic, and procedural safeguards to protect your personal information collected via our Services in compliance with applicable law. Please see the Terms of Use available via the Website homepage (“Terms”) for more specific information about information security and your responsibilities.
Where you use a Portal or other Service that is secured with a username and password, you are also responsible for taking steps to protect the privacy of Personal Information about you. In order to protect your privacy, you should:
If you share your Portal username and password with another person, this will allow that person to see your confidential medical record information. We have no responsibility concerning any breach of your confidential medical record information due to your sharing or losing your user name or password.
We will retain Personal Information for the period necessary to fulfill the purposes for which it has been collected as described in this Privacy Policy unless a longer retention period is required by law (e.g., laws mandating retention of medical records for a certain period of time).
Where practical, we dispose of certain categories of information, including Personal Information, on a regular schedule. For example, we dispose of information submitted through secure forms after 6 months, and information collected for analytics purposes on the Website (e.g., information on pages visited on the Website) after 5 years.
If you are a Portal user, you may access and amend personal demographic information when logged into the Portal. If you would like to access, amend, erase, export, object to, restrict the processing, or other Personal Information collected via our Services or any other request as described below by state law, you may submit a request or write to us at:
HCA Healthcare
Attention: Privacy Requests
One Park Plaza
Nashville, TN 37203
We will promptly review all such requests in accordance with applicable laws.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first contact us so we have an opportunity to address your concerns directly before you do so.
We may send certain messages, including electronic newsletters, notification of account statuses, and marketing communications on a periodic basis. If you wish to be removed from such messages, you may request to discontinue future ones. All such material will have information as to how to opt-out of receiving it, although certain messages (such as a secure message sent by a doctor or an account status update via the Portal), may be required by law and will not have opt-out capabilities.
Under California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personal information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us with a reference to California Disclosure Information.
We will endeavor to respond to such requests to information access within 30 days following receipt at the e-mail address stated above. If we receive your request at a different e-mail address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
This section only applies to California residents (“Consumers”). For the purposes of this section only, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household.
Consumers have the following rights:
You may submit requests for information by completing the Consumer Request Form, by emailing us at Personal Information Request or by calling us at 844-422-3282.
Please note, under California Law, that we are only required to respond to such requests from you twice in a twelve-month period.
When we collect your Personal Information offline, for example at an onsite event, a Notice at Collection may be printed on a sign-in sheet, a paper version of the Notice could be available at the entrance of the event or prominent signage will be displayed directing you to where the Notice can be found online. All options will provide information to you so that you can exercise your privacy rights listed above.
We do not have actual knowledge that we sell or share the Personal Information of Consumers who are less than 16 years of age. However, if we have actual knowledge that the Consumer is less than 16 years of age, we will not sell or share the Consumer’s Personal Information unless the Consumer in the case of Consumers who are at least 13 years of age and less than 16 years of age, or the Consumer’s parent or guardian, in the case of Consumers who are less than 13 years of age, has affirmatively authorized the disclosure of the Consumer’s Personal Information.
The categories of sources from which we collect Personal Information are:
The categories of third parties with whom we share Personal Information are described in detail in the “How We Disclose Personal Information” section of this Privacy Policy.
The chart below describes:
|
Category |
Examples |
Disclosed for a Business Purpose |
Sold or Shared |
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. |
Yes |
No |
| Personal Information categories described in Cal. Civ. Code § 1798.80(e) | Name, address, telephone number, insurance policy number, employment history, medical information, health insurance information. |
Yes |
No |
| Characteristics of protected classifications under California or federal law | Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
Yes |
No |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Yes |
No |
| Biometric information | Voice Recognition, Fingerprint and Palm Print Scanning, Facial Recognition, Iris Recognition, Keystroke, Gait, or other physical patterns, and Sleep, Health, or Exercise Data. |
No |
No |
| Internet or Electronic Network Activity Information | Browsing history, search history, Internet protocol address, type of browser, number of links clicked within our Services, state or country from which you accessed our Services, date and time of visit, name of Internet service provider, third party websites you linked to from our Services, pages or information you viewed on our Services, number of times you have viewed an ad. |
Yes |
No |
| Geolocation data | Region or postal code. |
Yes |
No |
| Audio, electronic, visual, thermal, olfactory, or similar information | Photographs, video recordings and voice/call recordings. |
No |
No |
| Professional or employment-related information | Work experience, name, phone number, email address, performance evaluations. |
Yes |
No |
| Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99) | Educational records such as transcripts, class lists, student course schedules, health records, student financial information, and student disciplinary records. |
Yes |
No |
| Inferences drawn from any Personal Information identified to create a profile about a consumer | A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
No |
No |
| Sensitive personal information: | Social security, driver’s license, state identification card, or passport number. |
No |
No |
| Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. |
No |
No |
|
| A consumer’s precise geolocation. |
No |
No |
|
| A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. |
No |
No |
|
| The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. |
No |
No |
|
| A consumer’s Genetic Data. |
No |
No |
|
| The processing of biometric information for the purpose of uniquely identifying a consumer. |
No |
No |
|
| Personal information collected and analyzed concerning a consumer’s health. |
No |
No |
|
| Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. |
No |
No |
The purposes for which the categories of Personal Information shall be used, and the business or commercial purposes for collecting or disclosing Personal Information, are described in detail in the following sections of this Privacy Policy:
We will retain Personal Information for the period necessary to fulfill the purposes for which it has been collected. In accordance with internal record retention policies, we dispose of all categories of Personal Information no later than 5 years from the date of collection unless a longer retention period is required by law, for security, fraud & abuse prevention, to comply with legal or regulatory requirements, to ensure continuity of services or financial record-keeping purposes. Consumer accounts in MyHealthOne are only deleted by the owner of the account and may exceed the five-year retention period. Information collected from a “Contact Us” webform may exceed the five-year retention period as it is a general communication form that sits on most websites to give website visitors the opportunity to ask general questions about the facility, its services or to leave comments. Employees can find the relevant record series codes in the Retention Schedules under Human Resources (HUM), which can be found in the applicable Workforce Notices posted internally, or by making a privacy rights request by following the instructions in this Privacy Policy.
We may collect the following categories of covered information about you through our Website, Portals, and Services when you visit the Website and Portals or use the Services such as:
We may share such covered information with categories of third parties such as marketing.
Third parties may collect covered information about your online activities over time and across different Internet websites or online services when you use the Website, Portals, or Services.
If you use or visit the Website and Portals or use the Services you may review and request changes to any of your covered information that is collected through the Website, Portals, or Services by calling 844-422-3282.
You may submit a verified request that we not sell any covered information that we have collected or will collect about you by calling 844-422-3282. After we receive your request and determine that it is a verified request, we will not sell any covered information that we have collected or will collect about you.
If you are visiting our Portal from outside the United States, your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. Although the data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, we take steps to protect your privacy, including, for transfers of Personal Information from the European Economic Area, the use of contractual clauses (known as “Model Clauses” or “Standard Contractual Clauses”) that have been approved by the European Commission. By using our Portal, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.
If you are one of our patients, your personal information in our possession is protected health information (“PHI”) protected by the Health Insurance Portability and Accountability Act of 1996, as amended (‘HIPAA’), and the applicable provisions of the Health Information Technology for Economic and Clinical Health (HITECH) Act. In addition to this Privacy Policy, the HIPAA Notices of Privacy Practices of those Provider facilities apply to your PHI.
In collecting Personal Information, our Services may also collect PHI. Just as we strive to protect Personal Information we are committed to protecting your PHI. If there is a breach of your PHI, we are required by law to notify you. Your PHI will only be disclosed to you or your personal representative, unless otherwise required or permitted by state or federal law. In all circumstances, unless otherwise required by law, we will obtain your written authorization before using or disclosing your PHI. This protection extends to PHI that is oral, written, or electronic.
If collected, we will take reasonable measures to protect the confidentiality of Social Security numbers and limit access to those with a need for such information. We prohibit the unlawful disclosure of Social Security numbers.
We will never ask for or knowingly collect Personal Information from children through the Services or Portal. If you are a child, you are not permitted to use the Portal and should immediately exit our Portal. Parents of un-emancipated minors may set up accounts for themselves to access their children’s medical records only as permitted pursuant to the Terms governing the Portal. If you think that we have collected personal information from a child through this Portal, please contact us and we will dispose of the information as required by applicable law.
We reserve the right to change the terms of this Privacy Policy at any time by posting those changes in revisions to this Privacy Policy, so that you are always aware of our processes related to collection, use and disclosure of information. We urge you to check here for any updates to this Privacy Policy from time to time. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Website.
If you have any questions or concerns about this Privacy Policy or the information practices of our Services, please contact us.
If you are a resident of the European Economic Area and have any questions or concerns about this Privacy Policy or the information practices of our Services, please contact our appointed EU representative, the DPO Centre.
You may also write to us at:
HCA Healthcare
Attention: Privacy Requests
One Park Plaza
Nashville, TN 37203