2023 Patient Impact Report: Clinical Outcomes Measures for Health System Specialty Pharmacy Services
Certain states maintain consumer privacy laws (CPLs) designed to give consumers privacy rights over the personal information that CPS collects. These consumer privacy laws require CPS to provide consumers a Notice, at or before the point of collecting personal information, which describes the categories of personal information collected, the business purposes for which CPS collects or uses the personal information, if the personal information will be sold or shared, and the intended retention period.
CPS collects personal information in connection with its marketing, application, and other internet websites, including but not limited to CPS.com, Azina.com, and Therigy.com, and through oral and written communications with CPS personnel. As discussed in more detail below, CPS discloses personal information to service providers and contractors for business purposes.
The following applies to CPS collection of Consumers Personal Information:
A. Categories of Consumer PI Collected.
CPS may collect the following categories of consumer PI:
B. Business Purposes for Collecting Consumer PI.
CPS uses consumer PI to:
C. Categories of Service Providers/ Contractors to Whom CPS Discloses Consumer PI.
CPS discloses consumer PI to the following categories of service providers / contractors:
• Identifiers (including name, mailing address, email address, IP address, phone number, or emergency contact).
• Comply with applicable laws.
• To personalize the consumers website experience and deliver content, products, and service offerings relevant to your interests.
• Contract management.
CPS will not use the personal information it collects for materially different, unrelated, or incompatible purposes than those listed above without first providing you notice.
D. Sources of Personal Information from Whom CPS Collects: CPS obtains the categories of personal information listed above from the following sources:
1. Directly from consumers through CPS’ websites when consumers voluntarily provide their personal information to CPS. Consumers may provide their personal information to CPS when they express interest in obtaining information about CPS or CPS products and services, participate in activities on the websites, purchase products or services, or complete a form requesting contact from CPS. The personal information CPS collects depends on the context of the consumers’ interaction with CPS and the websites, the choices they make, and the products and features they use.
2. Directly from consumers through verbal and written communications with CPS representatives, including job applications, reference materials, forms (including employment, payroll, and benefits administration), messaging applications, email, and the “Comments” section of the websites.
3. Indirectly from consumers by collecting information about their actions on CPS websites when consumers visit, use, or navigate the websites. This information does not reveal their specific identity but may include device and usage information, such as their IP address, browser, and device characteristics, operating system, language preference, referring URLs, device name, country, location, information about how and when they use CPS’ websites, and other technical information.
4. Indirectly from consumers by collecting information about their use of CPS resources. CPS automatically collect certain information when consumers log into and out of CPS information systems and when they access CPS properties and systems that are monitored with security system surveillance in the form of physical security, badge readers, and network security.
5. Public databases. CPS collects certain information about consumers through lawful use of public databases, including the OIG Exclusions Database and state licensure boards.
6. Service providers and contractors. CPS collects certain information about consumers from CPS’ services providers and contractors, including those that complete background surveys for CPS employment and contracting purposes, regularly monitor the OIG Exclusions Database, and coordinates recruitment and application processing.
7. CPS affiliates. CPS may receive personal information about consumers from ITS affiliates. CPS affiliates are also subject to this policy.
Selling or Sharing Your Personal Information. CPS does not sell or share consumer personal information with third parties.
Retention of the Personal Information CPS Collects. CPS will retain personal information for as long as needed or permitted considering the purpose(s) for which it was collected. The criteria used to determine CPS’ retention periods include:
1. The length of time CPS has an ongoing relationship with the consumer.
2. Whether CPS has a legal obligation to maintain or destroy personal information.
3. Whether retention is advisable considering CPS’ legal position such as regarding the enforcement of the website Terms and Conditions, applicable statutes of limitation, litigation, or regulatory investigations.
Contact CPS. For questions or concerns regarding how consumers’ personal information is used, please contact CPS by:
1. Submitting an email to CPS.Privacy@CPS.com
2. Calling CPS at 1-833-450-4229.
3. Submitting a written request by mail to CPS Solutions, LLC 655 Metro Place South Suite 450 Dublin, Ohio 43017-3520 ATTN: CPS Compliance Officer, Corporate Compliance Department.
Last updated: March 3, 2022