APDR Privacy Policy

About APDR

The Association of Program Directors in Radiology is an organization of residency and fellowship program directors and coordinators with the common goal of optimizing the educational experience for our trainees. Through an annual meeting, periodic communications, and material on its website, APDR enhances the professional capabilities of its members, provides them with the tools necessary to comply with regulatory requirements of the Residency Review Committee and the American Board of Radiology, and facilitates effective communication with those organizations and others with common interests.

 

You can contact us at:

Association of Program Directors in Radiology

820 Jorie Boulevard

Suite 200

Oak Brook, Illinois 60523, USA

APDR@rsna.org

Telephone: 1- 630-368-3737

 

For the purposes of European Union (EU) data protection law (in particular the General Data Protection Regulation, or “GDPR”, and its implementing laws at national level in the EU), we are controller of the processing of Personally Identifiable Information (PII), we describe in this Policy.

This Privacy Policy details how we process PII, including the personal data of individuals residing in the EU and the European Economic Area (EEA) when they interact with our services.

Types of Information Collected

We recognize personal data as any information related to an identified or identifiable individual. Depending on the context of your interactions with APDR, we collect and use different types of personal data from website visitors, members of our Association and others that interact with us.

Membership information: when applying for an APDR membership you will be asked to complete the appropriate form providing your contact and professional information. For certain positions you should also provide your photograph, bank details, and your authorization to verify your information with the appropriate licensing authorities or other relevant entities.

Accounts on our website: All members and customers have the possibility to create an online account. Besides the information you provide us when becoming a member, we also process your username, passwords, and we log your activity on the website.

Registration to events, conferences and the annual meeting: we organize different events and conferences, and usually require your contact details and financial details. Additional information may be required of registrants seeking additional services such as accommodation preferences.

Customer information: we work with a variety of nonprofit and commercial partners to support our mission through sponsorship at our Annual Meeting, journal administration, and other activities and collect information from them in the course of our interaction.

Marketing activities: e-mail addresses and information about the interaction with our communications (such as IP addresses, opens, click-through data) are collected. We may also send surveys and collect various responses to these surveys which may include contact and professional information. APDR may use this information to improve customer service, gather customer feedback and gauge interest in new products or services.

Videos and photos: we collect and use videos and photos of members and event attendees in publicly available educational and promotional materials. Some of them include testimonies of persons who authorized us to share their personal experiences.

There is other information that we collect automatically when you visit our site through the use of cookies or similar technologies, such as your IP address, browser type, access times.

Why We Process Your Personal Data

The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are one of our members or a website visitor.

We process personal data of applicants to membership for the purpose of verifying their credentials to see if they meet the criteria to become members and for the purpose of processing the membership fee.

We process personal data of our members when they log into their online accounts for the purpose of managing their membership and providing them membership related services.

We process personal data in the context of our educational content to properly award credit and provide evidence to third parties of awarded credit.

We process personal data of participants to our events for the purpose of organizing those events.

We process personal data in the context of marketing activities for the purposes of marketing our services and of communicating with our members and customers.

We process personal data of our members and customers to better discern and serve their needs and improve our products and services.

We process personal data in the context of videos and photos that we maintain, for the purposes of informing our members and the public about our activities.

We process personal data collected through cookies placed by our website to support the operation of our website and to analyze the traffic patterns on our site so as to provide better service to visitors and members.

We process personal data to maintain professional day to day business operations with our partners and vendors.

We process personal data (images and video) to promote and inform our members and the public about our activities and events.

For archiving purposes according to our internal regulations as a nonprofit membership organization.

We process personal data to comply with laws and enforcement requests, to enforce applicable agreements and policies for our services, to prevent fraud, and to comply with all applicable laws; including tax and other local regulations.

Our Policy Towards Children

Our services are not directed to children.

We do not knowingly collect personal data from children. We may incidentally process personal data of children, for instance where participants to our events travel with family or when images we capture for our gallery of videos are those of conditions suffered by children. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for our services and has provided us with personal data without the consent of their parent or guardian, we will delete such information from our files.

Disclosures to Third Parties

At times, APDR engages third party contractors, service providers, and other vendors to help us accomplish our business objectives. There are other circumstances where we are required by law to disclose personal data to third parties such as public bodies or judicial authorities.

We engage with our agents, representatives, contractors, service providers or other third parties for the following services:

authorization of credit card transactions (US based),

membership management (US based),

Marketing email and print partners (US based),

Education management partners (US based)

If the engagement involves the transmission of personal data, we require the service provider to treat that data consistent with this Policy. A contract to protect the personal data is executed before any data is disclosed, if that vendor will process personal data of individuals in the EU/EEA on our behalf.

APDR may also disclose information in special cases when it has a good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect and defend our rights or property; (c) enforce the Website Terms and Conditions of Use; or (d) act to protect the interests of our users or others. Occasionally APDR may be required by law enforcement or judicial authorities to provide personally identifiable information to the appropriate governmental authorities. We will disclose such information upon receipt of a court order or subpoena in cooperation with a law enforcement investigation. APDR reserves the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

Your European Privacy Rights

If you reside or otherwise find yourself in the European Economic Area (EEA), APDR is committed to process your personal data lawfully and facilitate the exercise of your rights granted by the European General Data Protection regulation (GDPR). You can contact us at any time to discuss your privacy concerns.

Legal basis for data collection and use:

We only collect and use personal data when there is a fair and legal basis for its collection and use, for instance, when the collection of personal data is necessary to become member of the Association, to meet our legitimate interests to send marketing material, to comply with legal obligations or when we have your authorization. See below the legal basis for each collection:

Membership information: necessity to enter into a contract or for the performance of a contract and legitimate interest

Registration to events, conferences and the annual meeting: necessity to enter into or for the performance of a contract. For certain processing of personal data in relation to our events, we rely on legitimate interest (e.g. taking photos during the event) to advance our mission as a membership organization in providing education and information.

Marketing activities: Consent for email marketing; our legitimate interests for marketing conducted other than through email or phone call;

Business information: necessity to enter into a contract or for the performance of a contract

Videos and photos: Legitimate interest for informational and educational activities with consent to use specific images and video

Journal submissions: necessity to enter or for the performance of a contract

Information collected automatically: consent

Privacy rights under the European regulation:

Transparency and the right to information: we provide notice to our members, website users and other third parties who interact with us of how we use personal data in our day-to-day activities at the time of collecting personal data, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.

Right to access, rectification, restriction of processing, erasure, and data portability: if you are based in the EEA we provide you with access to your own personal data. In addition, we will rectify your personal data when it is incorrect or inaccurate, and we will ensure the right to erasure, portability and to restriction of processing when these rights are not incompatible with other legal obligations.

Right to object and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced to ensure that it is not incompatible with local regulations or our legitimate interests.

These requests should be submitted as follows:

Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails or contacting us. You will still continue to receive emails relevant to course registrations or purchases (e.g. registration confirmations or purchase receipts) or necessary to your continued membership in APDR (e.g. dues notices).

To exercise the rest of your rights: you should send a communication in writing to:

Association of Program Directors in Radiology

Attn: Privacy

820 Jorie Boulevard

Suite 200

Oak Brook, Illinois 60523, USA

 

In order to fulfil this request, we may require you provide us information to verify your identity and specify your request. We will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.

If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority of your habitual residence, place of work or place of the alleged infringement.

International Transfers of Personal Data

If you are located outside the United States and you interact with our website or provide us personal data, then your personal data may be transferred to the United States.

We transfer your personal data to the United States whenever you interact with us.

The US has not sought, nor obtained adequacy status from the European Union. The EU-US Privacy Shield framework obtained an adequacy decision. The level of protection of your personal data is not deemed equivalent to the one in the EU, unless the receiving organization is self-certified under the EU-US Privacy Shield or implements other approved transfer mechanisms. As a not-for-profit organization, we are not able to adhere to the EU-US Privacy Shield Principles, nor implement other transfer mechanisms.

We transfer your personal data on the basis of the derogations in Article 49 GDPR, particularly:

Necessity to enter and for the performance of a contract for registration information to participate to our events; for processing personal data of our members to maintain their relationship with our organization, provide them services including when they log in to their member accounts; and also for processing personal data for online and offline courses.

Explicit consent, for newsletter subscribers and certain processing in relation to organizing events - such as storing photos, and marketing activities;

As for safeguards to your personal data, we directly apply the GDPR provisions to your personal data. As a matter of principle, we do not engage in any onward transfers regarding your data, beyond the access that our processors have to your data. We select carefully our processors and we require that provide equivalent safeguard mechanisms.

Data Security

APDR is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep all information obtained from our members, conference participants, and online visitors secure against unauthorized access and use and we periodically review our security measures.

Security measures:

We use identification and authentication processes to insure that access to PII is limited to RSNA and APDR employees who require it. Offsite access to sensitive information requires the use of a VPN. When compiling statistics, we anonymize member data and report on aggregate measures. We employ encryption technology to protect data at rest and in transit.

You should be aware, however, that “perfect security” does not exist on the Internet, and third parties may unlawfully intercept or access transmissions or private communications.

This site contains links to other sites. While APDR strives to link only to sites that share our high standards and respect for privacy, APDR is not responsible for the privacy practices employed by other sites.

APDR MAKES NO CLAIMS, PROMISES OR GUARANTEES ABOUT THE ACCURACY, COMPLETENESS OR ADEQUACY OF THE CONTENTS OF ITS SITE, AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS AND OMISSIONS IN THE CONTENTS OF THIS SITE. NO WARRANTY OF ANY KIND, IMPLIED, EXPRESSED OR STATUTORY, INCLUDING BUT NOT LIMITED TO THE WARRANTIES OF NON-INFRINGEMENT, TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND FREEDOM FROM COMPUTER VIRUS, IS GIVEN WITH RESPECT TO THE CONTENTS OF THIS WEBSITE OR ITS HYPERLINKS TO OTHER INTERNET RESOURCES. REFERENCE IN THIS WEBSITE TO ANY SPECIFIC COMMERCIAL PRODUCTS, PROCESSES OR SERVICES, OR THE USE OF ANY TRADE, FIRM OR CORPORATION NAME IS FOR THE INFORMATION AND CONVENIENCE OF THE PUBLIC AND DOES NOT CONSTITUTE ENDORSEMENT OR RECOMMENDATION BY APDR.

Retention Periods

APDR applies the storage limitation principle in order to retain personal data in our records only for the length of time required to fulfill the purpose for which the data was collected.

According to our retention policy, we only keep personal data in our records as long as they are necessary for the purposes they have been processed. The retention period depends on the context in which we process data, for instance:

3 years: complaints involving active members

7 years: CME activity data, contracts (after completion)

Permanent: membership application. Only this information is stored permanently for archiving purposes according to our internal regulations.

Changes to this Policy

We reserve the right to modify this Privacy Policy at any time. We will duly inform you of any changes.

APDR may occasionally update this privacy statement and other statements referenced by it as new services and programs are introduced.

These changes will be notified to you via an email communication and/or by placing a prominent notice on the Site. The time stamp you see on the policy will indicate the last date it was revised.

 

Approved by the Board of Directors: January 20, 2021