Ensuring the security and integrity of the Services is a stated use
Ensuring the security and integrity of the Services appears as a standalone use of the collected information, stated without further detail about the measures involved.
Supporting quotations
Ensure the security and integrity of our Services.
Not stated here
The section does not describe the security controls or standards applied.
Security & Safeguards · Company commitment
Biometric data is deleted at the first of three triggers, with a PHI carve-out
eCW says it retains biometric data only until the first of the following occurs, at which point the data is scheduled for deletion: the purposes outlined in Section 9 have been satisfied, a date of deletion required by applicable law, or three years have passed since the reader’s last interaction with the Services. Two qualifications follow: eCW will not delete biometric data that is PHI unless the applicable Provider requests it, and apart from that case the collection, use, storage, disclosure and retention of biometric PHI is governed by Section 4 and any applicable Customer Documents rather than by Section 9.
Supporting quotations
We will retain such biometric data only until the occurrence of the first of the following, at which point the data will be scheduled for deletion: (a) the purposes outlined in this Section 9 have been satisfied, (b) any date of deletion required by applicable law, or (c) three (3) years have passed since your last interaction with our Services. Notwithstanding the foregoing, (1) eCW will not delete biometric data that is PHI unless requested by the applicable Provider, and (2) except as provided in subsection (1), the collection, use, storage, disclosure, and retention of biometric data that is PHI through the use of any of the Services shall be governed by Section 4 of this Privacy Policy and any applicable Customer Documents, not by this Section 9.
Qualifications & exceptions
Deletion is triggered by the earliest of the three events.
The retention commitment is displaced for PHI, which follows the Provider’s instruction and Section 4.
Not stated here
What “scheduled for deletion” means operationally is not described.
Security & Safeguards · Company commitment
eCW claims reasonable safeguards while conceding no system is perfect
eCW says it has reasonable and appropriate safeguards in place to help protect collected Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. It immediately qualifies this by saying that although it attempts to protect the information in its possession, no security system is perfect and it cannot promise that Personal Information will remain absolutely secure in all circumstances.
Supporting quotations
eCW has reasonable and appropriate safeguards in place to help protect the Personal Information eCW collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Although eCW attempts to protect the Personal Information in our possession, no security system is perfect, and eCW cannot promise that your Personal Information will remain absolutely secure in all circumstances.
Qualifications & exceptions
The safeguard commitment is framed as “reasonable and appropriate” rather than as a guarantee.
The paragraph expressly disclaims absolute security in all circumstances.
Not stated here
No specific standard, certification or control set is named here.
Security & Safeguards · Company practice
Retention lasts as long as needed for purposes, business needs and legal obligations
eCW says it will retain Personal Information as needed to fulfil the purposes for which it was collected, and as necessary to comply with its business requirements and legal obligations, resolve disputes, protect its assets and enforce its agreements. It points California residents to a separate Privacy Notice for California Residents for further retention detail.
Supporting quotations
eCW will retain your Personal Information as needed to fulfill the purposes for which it was collected. eCW will retain and use your Personal Information as necessary to comply with eCW's business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. Additional information for California residents about our data retention practices is available in our Privacy Notice for California Residents.
Qualifications & exceptions
Retention is framed by purpose and by the listed business and legal needs, without fixed periods here.
Not stated here
The retention periods themselves are not stated in this section.
Security & Safeguards · Context
Security questions and incident reports go to the Chief Information Security Officer
Separately, readers with security questions or concerns, or who need to report a security incident, are directed to the eCW Chief Information Security Officer at the same Westborough address, marked for that officer, using the ciso.office contact given in the block.
Supporting quotations
If you have any questions or concerns related to Security or if you need to report a Security incident, please contact the eCW Chief Information Security Officer at:
eClinicalWorks, LLC 2 Technology Drive Westborough, MA 01581 Attn: Chief Information Security Officer ciso.office
Not stated here
The contact block in the source ends with the local part of the address, so the full e-mail address is not reproduced in the evidence.
Security & Safeguards · Company commitment
Breach notices go to account contact details unless law requires another method
Where applicable law requires notice of known or suspected security breaches affecting the reader’s Personal Information, eCW says it will send breach notices to the contact information in the reader’s account unless the law requires a different method. For other events involving information about the reader, it may contact the reader by e-mail, telephone or mail.
Supporting quotations
Pursuant to applicable law, eCW may be required to send you notice of known or suspected security breaches that impact your Personal Information. In the event that eCW must provide a notice of a security breach to you, eCW will send security breach notices to the contact information contained in your account information unless eCW is required by law to notify you using another method. Otherwise, if eCW needs, or is required, to contact you concerning any event that involves information about you we may do so by e-mail, telephone, or mail.
Qualifications & exceptions
The notice obligation is framed by what applicable law requires.
The default channel is the account contact information.
Not stated here
Timing of breach notices is not specified in this paragraph.
Security & Safeguards · Company practice
Security, integrity and detecting or prosecuting misconduct are listed purposes
The list includes helping maintain the safety, security and integrity of eCW’s website, products, services, databases and other technology assets and its business, and detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and assisting in the prosecution of those responsible.
Supporting quotations
Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and assist in the prosecution of those responsible for that activity
Qualifications & exceptions
The incident purpose expressly extends to assisting prosecution.
Not stated here
The notice does not describe the security measures or how incidents are detected.
Security & Safeguards · Company commitment
De-identified data will not be re-identified to answer a rights request
Where eCW retains CCPA/CPRA Personal Information only in de-identified form, it says it will not attempt to re-identify the data in response to a consumer rights request.
Supporting quotations
Additionally, if we retain your CCPA/CPRA Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a Consumer Rights request.
Qualifications & exceptions
The commitment is limited to information retained only in de-identified form.