Spotify
Date signed: 9/30/2019
| TPWA PIA Questions | TPWA PIA Answers |
|---|---|
| OPDIV: | CMS |
| TPWA Unique Identifier (UID): | T-3699699-318923 |
| Is this a new TPWA? | Yes |
| 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 Spotify to deliver behaviorally targeted digital advertising to identify relevant audience by tracking user online activities across various websites over time and by utilizing first party data provided to Spotify at the time of account creation. Spotify does not collect PII in the course of these advertising activities and therefore, does not share PII with CMS. Spotify 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 Spotify 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 Spotify, 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? | Other... |
| Please describe how the public navigate to the third-party website or application: | Not Applicable. The CMS websites do not link to Spotify. Spotify is a tool used to place and track advertising within the Spotify application. |
| 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 Spotify |
| 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. Spotify does not collect or share PII. If a consumer chooses to connect their Spotify account through a third-party service such as Facebook, data may be shared with that partner but only through consent with the end user. |
| If PII is shared, how are the risks of sharing PII mitigated? | Not applicable. Spotify does not collect or share PII. |
| Will the PII from the third-party Website or application be maintained by the OPDIV? | Not applicable. Spotify does not collect or share PII. |
| 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 Spotify’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 Spotify solely for the purposes of improving consumer engagement with CMS websites by directing consumers to CMS websites through the use of targeted advertising. 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. Additional Background: Spotify 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 Spotify 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. 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. Mitigation: CMS and Spotify provide consumers with information about the use of persistent cookies and related technologies. Spotify also offers users the ability to opt-out of having Spotify advertising cookies through the following process: Opt-out of tailored advertising at: https://www.spotify.com/us/account/privacy/ |
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