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Health Internet Ethics:
Ethical Principles For offering
Internet Health Services to Consumers
As Hi-Ethics members, we are committed to ensuring that individual consumers
can realize the full benefits of the Internet to improve their
health and that of their families. To fulfill our
commitment, we are dedicated to meeting the following goals:
- Internet health services that reflect high quality and ethical standards;
- Providing health information that is trustworthy and up-to-date;
- Clearly identifying online advertising and disclosing sponsorships or other
financial relationships that significantly affect our content or services;
- Keeping personal information private and secure, and employing special
precautions for any personal health information; and
- Empowering consumers to distinguish online health services that follow our
principles from those that do not.
We believe that in living by
these principles, we can improve the consumers experience
with online health information and services. We have
provided a glossary of terms with special meanings at the end of
this document.
1. Privacy Policies
Our members will adopt a privacy policy that is easy for
consumers to find, read, and understand. Our privacy policies will —
- Provide users with reasonable notice of our information
practices, including disclosure of —
- collection or use of any information about the user;
- collection or use of aggregate data; and
- what, if any, access to personal information collected on our health web site we
provide to unrelated third parties.
- Provide consumers with a meaningful choice on our health
web site to accept or decline our proposed collection and use of
personal information provided by the consumer including, if any,
consent to the transfer of information to third parties.
- Contain a positive commitment from us to use security
procedures to protect personal information we collect from misuse.
- Provide, where appropriate, procedures for consumers to
review and correct their personal information that we maintain, or to
request that we delete the information, and include a description of
the effect of any changes on other information about the user that we
maintain.
2. Enhanced Privacy Protection for
Health-Related Personal Information
- If we collect health-related personal information, we will only
use it for the purposes for which a reasonable consumer would
expect us to use it or as agreed to by the consumer.
- We will not disclose health-related personal information to an
unrelated third party and/or for unrelated purposes without first
obtaining the consent of the consumer (by means of an explicit
"opt-in" procedure)
.
- When we make significant changes to our privacy policies that
affect the use of the health-related personal information we collect,
we will give notice to our users. We will not make use of information
we gathered from individuals prior to a significant change in policy
without first obtaining their consent for any new uses. We may also
make non-significant changes to our privacy policies that will not
affect our use of a consumer’s personal information. We will post
such changes on our health web site.
3. Safeguarding Consumer Privacy in
Relationships with Third Parties
- Where third parties have access to health-related personal
information from our site, our agreements with these third parties
will follow these principles in giving consumers notice and choice
with respect to that third party’s access and use.
- Where we have relationships with third parties, we will adopt
procedures to tell consumers if third parties have access to personal
information about them from our site
.
- We will take appropriate precautions to prevent inadvertent
disclosures of personal information to third parties and will take
immediate steps to eliminate such disclosures, if they occur, once
they have come to our attention.
- We will not allow third parties any access to non-personal
individual information collected on our site unless the third party
agrees that it will not use the information to identify individuals.
4. Disclosure of Ownership and Financial
Sponsorship
We will disclose those who have major financial interests in
us or the health web sites we operate, and those who give us
significant funding or other assistance. We will:
- Clearly state who owns any health web site we operate.
- Clearly identify those who hold an ownership interest of 10% or more in
our company, and those whose financial contributions to our health web site represent
10% or more of the annual revenues of our company. Financial contributions mean
both cash and in-kind services or materials by persons who are not otherwise
identified as sponsors.
5. Identifying Advertising and Health Information
Content Sponsored by Third Parties
- We will clearly distinguish advertising from health information
content, using identifying words, design, or placement. We will
design our health web sites to avoid confusion between advertising
and health information content.
- We will clearly disclose significant relationships between
commercial sponsors and our health information content by
identifying a sponsor’s involvement in —
- selecting or preparing health information content that appears on our health
web site, including any sponsorship of priority listings in search engine results,
product listings, or other preferences in presentation of information to consumers; and
- any "co-branding" of health information content or Internet health services.
- We will provide consumers with a policy that is easy for
consumers to find, read and understand regarding our acceptance of
advertising and of health information content sponsored by others.
Our policy will disclose —
- how we identify advertising and commercially sponsored health information
content on our health web site;
- how we may obtain revenues from third parties related to advertising and
health information content sponsored by others on our health web site, including
advertising revenues, commissions on consumer purchases, fees based on consumer
use of links to other web sites, and revenues for transfer or use of information about
users, including aggregate data;
- whether we target advertising or sponsored health information content to
consumers based on information about them or their use of our health web site; and
- whether we intend any links to other web sites, logos, or marks of other
companies, or any co-branding to constitute recommendations to the consumer
.
6. Promotional Offers, Rebates, and Free Items or
Services
We will comply with existing federal and state laws regarding
any promotions, rebates, or free or discounted offers on our health
web site.
7. Quality of Health Information Content
- We will not make claims of therapeutic benefit without
reasonable support, or deliberately provide false or misleading
information.
- We will not accept advertising or sponsored health
information content that we know either contains false or misleading
claims or promotes ineffective or dangerous products.
- We will have an editorial policy that is easy for consumers to
find, read, and understand. Our editorial policy will describe
procedures we use for evaluating the quality of the health information
content on our health web site, whether created by us or obtained
from others.
8. Authorship and Accountability
- We will disclose any cases where we have placed health
information content on our health web site because of sponsorship or
other support from a third party. In addition to identifying the
sponsor, we will clearly disclose significant relationships between the
commercial sponsor and our health information content by identifying
the sponsor’s involvement with that content.
- Where we reproduce health information content created by
third parties, we will clearly disclose the author and/or source of the
material and the date of the material or its last update.
- Where we present health information content as the result of
clinical experience or scholarly research, we will clearly disclose the
actual author(s) of the health information content.
- Where we create health information content for use by
consumers, we will provide consumers general information about our
authors and their qualifications, our editorial policy, and, if any, our
expert review process.
- Where we create health information content, we will clearly
disclose the date it was created or last updated.
- We will have a conflict of interest policy for all authors that is
easy for consumers to find, read, and understand. We will disclose
all affiliations and financial relationships of authors consistent with
our policy.
9. Disclosure of Source and Validation for
Self-Assessment Tools
- Where we offer self-assessment tools, we will disclose their
source and appropriately describe the scientific basis for their
operation.
- We will also describe how we maintain self-assessment tools,
including a description of any formal evaluation process and the date
of the last review or update.
10. Professionalism
- We believe that current codes of ethics apply when health
care professionals use health web sites to provide professional care.
However, these codes do not apply to every interaction between a
consumer and a professional. Our health web sites shall provide
conspicuous and appropriate information for consumers to
understand when they are and are not in an interaction with a health
professional that is covered by the ethical standards of the profession.
- Where we allow health care professionals to engage in
professional care on our health web sites, we will design Internet
health services to enable health care professionals to adhere to
professional ethical principles in the online environment. We will
continue to evolve new standards of practice to meet the changing
expectations created by consumers' use of Internet health services.
- Internet health services directed to and for use by health care
professionals are beyond the scope of these principles.
11. Qualifications
- We will provide the credentials and qualifications of persons
responsible for health care services delivered via our consumer
health web site. If applicable, we will also provide information about
professional licensure.
- We will disclose whether we verify information regarding
health care professionals or others who provide services or
information on our health web site.
12. Transparency of Interactions, Candor and
Trustworthiness
- We will inform consumers who use our Internet health
services of the risks, responsibilities, and reasonable expectations
associated with their use of our services. We will make sure that
this information is easy for consumers to find, read, and understand.
- We will strive to make it apparent to consumers when they
move within a site or leave one site for another and when the move
changes the risks, responsibilities, and expectations associated with
their activities.
13. Disclosure of Limitations
We will advise consumers of any limitations of our health web
site as a source of health care services. In particular, we will state
that online health services and health information content cannot
replace a health professional-patient relationship, and that
consumers should always consult with a professional for diagnosis
and treatment of their specific health problems.
14. Mechanism for Consumer Feedback
We will make it easy for consumers to provide us with
feedback or complaints concerning our health web sites.
* * *
Founding members of Hi-Ethics intend to implement these principles within
six months. Contracts with a third party and a health web site in effect when these principles
are adopted need not be amended if the health web site has a good faith belief that the contract
is in compliance with the Principles set forth herein.
HI-ETHICS GLOSSARY
For purposes of the Hi-Ethics Principles--
- AGGREGATE DATA means personal information or non-personal individual
information collected from a group of users that has been processed so that it can no longer be
used to identify a single, unique individual.
- CO-BRANDING refers to the joint branding of a web page or section of a consumer
health web site between two or more corporate entities or individuals. Co-branding may
involve the joint operation of services, health information content or products that appear on
a consumer health web site.
- HEALTH INFORMATION CONTENT includes information to help consumers stay
well, prevent and manage disease, and make decisions related to health and health care,
including information for making decisions about health-related products and health services.
It may be in the form of data, text, graphics, audio or video, and may involve special software
or hardware and programming enhancements that support interactivity. Health information
content includes both materials authored by third parties (whether scholarly works by
scientists and clinicians or interpretive articles prepared for consumers) as well as materials
created specifically for use on a health web site.
- HEALTH-RELATED PERSONAL INFORMATION refers to personal information
that is associated with health issues, categories, questions, and facts obtained as a result of the
individual's responses and activities on a health web site.
- INTERNET HEALTH SERVICES means the full range of services and activities
available on a consumer health web site. Examples include the sale of health care products,
delivery of health care services and health information, specialized health information
searches, self-assessment tools and activities, bulletin boards, chat rooms with and without
participation by health professionals, and opportunities for relationships and communication
with health care professionals and health plans.
- NON-PERSONAL INDIVIDUAL INFORMATION does not include any information
that would meet the definition of personal information (below), but may include information
about a specific individual's characteristics, preferences, interests, experiences, and activities
disclosed by the individual to the health web site or obtained through the individual's use of
the health web site.
- OPERATE refers to the degree of control a corporation or individual has over the
operations of a consumer health web site. A corporation or individual operates a consumer
health web site if the corporation or individual is primarily responsible for the material that
appears on the site including, but not limited to, advertising, health information content,
services and products.
- OPT-IN means an affirmative ability for a consumer to accept terms and conditions.
- PERSONAL INFORMATION means any individually identifiable information about an
individual collected online, including a first and last name, a home or other physical address,
including street name and name of a city or town, an E-mail address, a telephone number, a
Social Security number, or any other identifier that may permit the physical or online
contacting of a specific individual.
- SELF-ASSESSMENT TOOLS refers to online forms that allow an individual to
supply personal information and health-related information that cause interactive software
programming using medical knowledge to reach conclusions that may be relevant to
optimizing health care decisions or possible health outcomes.
- UNRELATED THIRD PARTY refers to a corporate entity or individual who acts on its
own behalf and in its own interest and to carry out a purpose other than that for which the
individual accessed the consumer health web site.
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