MiQ Digital USA Inc.
Date signed: 10/26/2018
| TPWA PIA Questions | TPWA PIA Answers |
|---|---|
| OPDIV: | CMS |
| TPWA Unique Identifier (UID): | T-9249624-092368 |
| Is this a new TPWA? | Yes |
| Please provide the reason for revision. | Not applicable |
| Will the use of a third-party Website or application create a new or modify an existing HHS/OPDIV System of Records Notice (SORN) under the Privacy Act? | No |
| Indicate the SORN number (or identify plans to put one in place.) |
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| Will the use of a third-party Website or application create an information collection subject to OMB clearance under the Paperwork Reduction Act (PRA)? | No |
| Indicate the OMB approval number and approval number expiration date (or describe the plans to obtain OMB clearance.) |
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| Does the third-party Website or application contain Federal Records? | No |
| Describe the specific purpose for the OPDIV use of the third-party Website or application: | CMS will use MiQ to deliver behaviorally targeted digital advertising to identify relevant audience by tracking user online activities across various websites over time. MiQ does not collect PII in the course of these advertising activities and therefore, does not share PII with CMS. MiQ provides CMS with conversion tracking reports to allow CMS to determine the effectiveness of advertising campaigns. Conversion tracking provides information about users’ activities regarding ads, including whether an ad is clicked on or a transaction is completed. The CMS websites which may utilize MiQ are; www.CMS.gov, www.Medicare.gov, www.MyMedicare.gov, www.Medicaid.gov, www.InsureKidsNow.gov, HealthCare.gov, and CuidadoDeSalud.gov. |
| Have the third-party privacy policies been reviewed to evaluate any risks and to determine whether the Website or application is appropriate for OPDIV use? | Yes |
| Describe alternative means by which the public can obtain comparable information or services if they choose not to use the third-party Website or application: | If consumers do not want to interact with advertisements from MiQ, consumers can learn about CMS campaigns through other advertising channels such as TV, radio, CMS websites and in-person events. |
| Does the third-party Website or application have appropriate branding to distinguish the OPDIV activities from those of nongovernmental actors? | No |
| How does the public navigate to the third party Website or application from the OPIDIV? | Not Applicable. The CMS websites do not link to MiQ. MiQ is a tool used to place and track advertising on third-party sites. |
| Please describe how the public navigate to the third-party website or application: | Not applicable. The CMS websites do not link to MiQ. MiQ is a tool used to place and track advertising on third-party sites. |
| If the public navigate to the third-party website or application via an external hyperlink, is there an alert to notify the public that they are being directed to a nongovernmental Website? | No |
| Has the OPDIV Privacy Policy been updated to describe the use of a third-party Website or application? | Yes |
| Provide a hyperlink to the OPDIV Privacy Policy: | https://www.cms.gov/privacy/ Is the privacy policy for all CMS websites unless a separate one is noted below. https://www.healthcare.gov/privacy/ https://www.medicare.gov/privacy-policy/index.html |
| Is an OPDIV Privacy Notice posted on the third-party Website or application? | No |
| Is PII collected by the OPDIV from the third-party Website or application? | No |
| Will the third-party Website or application make PII available to the OPDIV? | No |
| Describe the PII that will be collected by the OPDIV from the third-party Website or application and/or the PII which the public could make available to the OPDIV through the use of the third-party Website or application and the intended or expected use of the PII: | Not applicable. CMS does not collect any PII through the use of MiQ. |
| Describe the type of PII from the third-party Website or application that will be shared, with whom the PII will be shared, and the purpose of the information sharing: | Not applicable. MiQ does not collect or share PII. |
| If PII is shared, how are the risks of sharing PII mitigated? | Not applicable. MiQ does not collect or share PII. |
| Will the PII from the third-party Website or application be maintained by the OPDIV? | No |
| Describe how PII that is used or maintained will be secured: | Not applicable |
| What other privacy risks exist and how will they be mitigated? | CMS will conduct periodic reviews of MiQ’s privacy policy to ensure its policies continue to align with agency objectives and privacy policies and do not present unreasonable or unmitigated risks to user’s privacy interests. CMS uses MiQ solely for the purposes of improving consumer engagement with CMS websites by directing consumers to CMS websites through the use of targeted advertising. Use of Cookies and Web Beacons for Targeted Advertising Based on Sensitive Information Potential Risk: The use of cookies, pixels, and web beacons generally presents the risk that an application could collect information about a user’s activity on the Internet for purposes that the users did not intend. The unintended purposes include providing users with behaviorally targeted advertising, based on information the individual user may consider to be sensitive. In addition, MiQ uses data segments to profile users for advertising purposes, including health-related segments. Use of these segments to deliver CMS advertising to these populations may be considered by some individuals to be delivering advertising based on sensitive criteria. Additional Background: MiQ collects non-personally identifiable information by placing a cookie or pixel (also known as a web beacon) on CMS websites and on advertisements sponsored by CMS on third party websites. The non-personally identifiable information collected by MiQ may include; IP address, browser types, operating systems, domain names, access dates and times, referring website addresses, online transactions and browsing and search activity. A pixel (or web beacon) is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page that allows MiQ to collect information regarding the use of the web page. A cookie is a small text file stored on a website visitor’s computer that allows the site to recognize the user and keep track of preferences. These technologies provide information about when a visitor clicks on or views an advertisement. MiQ uses that information to judge which advertisements are more appealing to users and which result in greater conversions, such as transactions with CMS websites. CMS advertising displayed through MiQ will carry persistent cookies that enable CMS to display advertising to individuals who have previously visited CMS websites. In this instance, the persistent cookie will be stored on the user’s computer for up to 180 days, unless removed by the user. Mitigation: CMS and MiQ provide consumers with information about the use of persistent cookies and related technologies. This information includes what data is collected and the data gathering choices included in their website privacy policies, including choices related to behaviorally targeted advertising. Tealium iQ Privacy Manager is a tool that keeps track of users’ preferences in reference to tracking and will prevent web beacons from firing when a user has opted out of tracking for advertising purposes. When a user is routed to CMS websites by clicking on a CMS advertisement displayed through MiQ and the Tealium iQ Privacy Manager is present on CMS websites, users are able to control which cookies they want to accept from CMS websites. Tealium iQ Privacy Manager can be accessed through information provided on the privacy policy on CMS websites. There is a large green “Modify Privacy Options” button that turns off the sharing of data for advertising purposes that can be accessed through the CMS website’s privacy policy. The ability to control which cookies users want to accept is only valid when Tealium iQ Privacy Manager is installed on the website. Another alternative is for users to disable cookies through their web browser. Separately, CMS includes the Digital Advertising Alliance AdChoices icon on all targeted digital advertising. The AdChoices icon is an industry standard tool that allows users to opt out of being tracked for advertising purposes, like the Tealium iQ Privacy Manager. MiQ also agrees to delete all cookies and any data associated with these cookies upon request by CMS. MiQ also offers users the ability to opt-out of having MiQ advertising cookies through the following process: • Click on the “Ad Choices” logo in the corner of an ad served by MiQ; and • MiQ participates in the Digital Advertising Alliance (DAA), which provides consumers with the ability to opt-out of data collection for behavioral advertising by all companies who participate in the DAA. |
Third-Party Web and Application (TPWA) Privacy Impact Assessment (PIA) published by CMS as an Operating Division of the U.S. Department of Health and Human Services