Snapchat 2022
Date signed: 4/26/2022
| TPWA PIA Questions | TPWA PIA Answers |
|---|---|
| OPDIV: | CMS |
| TPWA Unique Identifier (UID): | T-9755910-082941 |
| 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.) | Not applicable. |
| 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.) | Not applicable. |
| 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 Snapchat to deliver behaviorally targeted digital advertising. Snapchat does not collect PII in the course of these advertising activities and therefore, does not share PII with CMS. Snapchat 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. |
| 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 Snapchat Ads, consumers can learn about CMS campaigns through other advertising channels such as TV, radio, CMS websites, and 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? | Other... Not Applicable. The CMS websites do not link to Snapchat. Snapchat is an independent app which includes space for advertising and provides advertisers with a tool used to place and track digital advertising. |
| Please describe how the public navigate to the third-party website or application: | Not Applicable. The CMS websites do not link to Snapchat. Snapchat is an independent app which includes space for advertising and provides advertisers with a tool used to place and track digital advertising. |
| 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/ 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 Snapchat nor will Snapchat make available any PII to CMS. |
| 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. Snapchat does not collect or share PII. |
| If PII is shared, how are the risks of sharing PII mitigated? | Not Applicable. Snapchat 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. Snapchat does not collect or share PII. |
| What other privacy risks exist and how will they be mitigated? | CMS will conduct periodic reviews of Snapchat 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 Snapchat 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, Snapchat uses data segments to profile users for advertising purposes. 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: Snapchat 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 Snapchat may include; plan type, IP address, browser types, operating systems, domain names, access dates and times and app interaction, referring website addresses, online transactions, browsing and search activity, device IDs and network type and service provider. 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 Snapchat 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. Snapchat 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 Snapchat 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 Snapchat 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 Snapchat 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. Snapchat also agrees to delete all cookies and any data associated with these cookies upon request by CMS. Snapchat also offers users the ability to control the use of their data for advertising through the following process: Opt-out of tailored advertising at: https://support.snapchat.com/en-GB/a/advertising-preferences |
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