Health
Internet Ethics:
Ethical Principles For Offering
Internet Health Services to Consumers
As Hi-Ethics members, we are committed to ensuring that individual
consumers can realize the full benefits of the Internet to improve their
health and that of their families. To
fulfill our commitment, we are dedicated to meeting the following goals:
- Internet health services that reflect high quality
and ethical standards;
-
Providing health information that is trustworthy and
up-to-date;
-
Keeping personal information private and secure, and
employing special precautions for any personal health information; and
-
Empowering
consumers to distinguish online health services that follow our principles
from those that do not.
Informed
by these goals, we adopt the following ethical principles.
We believe that in living by these principles, we can improve the
consumer's experience with online health information and services.
We have provided a glossary of terms with special meanings at the end
of this document.
1. Privacy Policies
Our members will adopt a privacy policy that is easy for consumers
to find, read, and understand.
Our privacy policies will --
A. Provide users with reasonable notice of our information
practices, including disclosure of --
1.
collection or use of any information about the user;
2.
collection or use of aggregate data; and
3.
what, if any, access to personal information collected on our health
web site we provide to unrelated third parties.
B. Provide consumers with a meaningful choice on our health web site to
accept or decline our proposed collection and use of personal information
provided by the consumer including,
if any, consent to the transfer of information to third parties.
C. Contain a positive commitment from us to use security procedures to
protect personal information we collect from misuse.
D. Provide, where appropriate, procedures for consumers to review and
correct their personal information that we maintain, or to request that we
delete the information, and include a description of the effect of any changes
on other information about the user that we maintain.
2. Enhanced Privacy Protection for Health-Related Personal Information
A. If we collect health-related personal information, we will only use it
for the purposes for which a reasonable consumer would expect us to use it or
as agreed to by the consumer.
B. We will not disclose health-related personal information to an
unrelated third party and/or for unrelated purposes without first obtaining
the consent of the consumer (by means of an explicit "opt-in"
procedure).
C. When we make significant changes to our privacy policies that affect
the use of the health-related personal information we collect, we will give
notice to our users. We will not
make use of information we gathered from individuals prior to a significant
change in policy without first obtaining their consent for any new uses.
We may also make non-significant changes to our privacy policies that
will not affect our use of a consumer's personal information.
We will post such changes on our health web site.
3. Safeguarding Consumer Privacy in Relationships with Third Parties
A. Where third parties have access to health-related personal information
from our site, our agreements with these third parties will follow these
principles in giving consumers notice and choice with respect to that third
party's access and use.
B. Where we have relationships with third parties, we will adopt
procedures to tell consumers if third parties have access to personal
information about them from our site.
C. We will take appropriate precautions to prevent inadvertent disclosures
of personal information to third parties and will take immediate steps to
eliminate such disclosures, if they occur, once they have come to our
attention.
D. We will not allow third parties any access to non-personal individual
information collected on our site unless the third party agrees that it will
not use the information to identify individuals.
4. Disclosure of Ownership and Financial Sponsorship
We will disclose those who have major financial interests in us or
the health web sites we operate, and those who give us significant funding
or other assistance. We will --
A. Clearly state who owns any health web site we operate.
B. Clearly identify those who hold an ownership interest of 10% or more in
our company, and those whose financial contributions to our health web site
represent 10% or more of the annual revenues of our company.
Financial contributions means both cash and in-kind services or
materials by persons who are not otherwise identified as sponsors.
5. Identifying Advertising and Health Information Content Sponsored by
Third Parties
A. We will clearly distinguish advertising from health information
content, using identifying words, design, or placement.
We will design our health web sites to avoid confusion between
advertising and health information content.
B. We will clearly disclose significant relationships between commercial
sponsors and our health information content by identifying a sponsor's
involvement in --
1. selecting or preparing health information content that appears on our
health web site, including any sponsorship of priority listings in search
engine results, product listings, or other preferences in presentation of
information to consumers; and
2. any "co-branding" of health information content or Internet
health services.
C. We will provide consumers with a policy that is easy for consumers
to find, read and understand regarding our acceptance of advertising and
of health information content sponsored by
others. Our policy will disclose --
1. how we identify advertising and commercially sponsored health
information content on our health web site;
2. how we may obtain revenues from third parties related to advertising
and health information content sponsored by others on our health web site,
including advertising revenues, commissions on consumer purchases, fees based
on consumer use of links to other web sites, and revenues for transfer or use
of information about users, including aggregate data;
3. whether we target advertising or sponsored health information content
to consumers based on information about them or their use of our health web
site; and
4. whether we intend any links to other web sites, logos, or marks of
other companies, or any co-branding to constitute recommendations to the
consumer.
6. Promotional Offers, Rebates, and Free Items or Services
We will comply with existing federal and state laws regarding any
promotions, rebates, and free or discounted offers on our health web sites.
7. Quality of Health Information Content
A. We will not make claims of therapeutic benefit without reasonable
support, or deliberately provide false or misleading information.
B. We will not accept advertising or sponsored health information content
that we know either contains false or misleading claims or promotes
ineffective or dangerous products.
C. We will have an editorial policy that is easy for consumers to find,
read, and understand. Our
editorial policy will describe procedures we use for evaluating the quality of
the health information content on our health web site, whether created by us
or obtained from others.
8. Authorship and Accountability
A. We will disclose any cases where we have placed health information
content on our health web site because of sponsorship or other support from a
third party. In addition to
identifying the sponsor, we will clearly disclose significant relationships
between the commercial sponsor and our health information content by
identifying the sponsor's involvement with that content.
B. Where we reproduce health information content created by third parties,
we will clearly disclose the author and/or source of the material and the date
of the material or its last update.
C. Where we present health information content as the result of clinical
experience or scholarly research, we will clearly disclose the actual author(s)
of the health information content.
D. Where we create health information content for use by consumers, we
will provide consumers general information about our authors and their
qualifications, our editorial policy, and, if any, our expert review process.
E. Where we create health information content, we will clearly disclose
the date it was created or last updated.
F. We will have a conflict of interest policy for all authors that is easy
for consumers to find, read, and understand.
We will disclose all affiliations and financial relationships of
authors consistent with our policy.
9. Disclosure of Source and Validation for Self-Assessment Tools
A. Where we offer self-assessment tools, we will disclose their source and
appropriately describe the scientific basis for their operation.
B. We will also describe how we maintain self-assessment tools, including
a description of any formal evaluation process and the date of the last review
or update.
10. Professionalism
A. We believe that current codes of ethics apply when health care
professionals use health web sites to provide professional care.
However, these codes do not apply to every interaction between a
consumer and a professional. Our
health web sites shall provide conspicuous and appropriate information for
consumers to understand when they are and are not in an interaction with a
health professional that is covered by the ethical standards of the
profession.
B. Where we allow health care professionals to engage in professional care
on our health web sites, we will design Internet health services to enable
health care professionals to adhere to professional ethical principles in the
online environment. We will
continue to evolve new standards of practice to meet the changing expectations
created by consumers' use of Internet health services.
C. Internet health services directed to and for use by health care
professionals are beyond the scope of these principles.
11. Qualifications
A. We will provide the credentials and qualifications of persons
responsible for health care services delivered via our consumer health web
sites. If applicable, we will
also provide information about professional licensure.
B. We will disclose whether we verify information regarding health care
professionals or others who provide services or information on our health web
sites.
12. Transparency of Interactions, Candor and Trustworthiness
A. We will inform consumers who use our Internet health services of the
risks, responsibilities, and reasonable expectations associated with their use
of our services. We will make
sure that this information is easy for consumers to find, read, and
understand.
B. We will strive to make it apparent to consumers when they move within a
site, or leave one site for another, and when the move changes the risks,
responsibilities, and expectations associated with their activities.
13. Disclosure of Limitations
We will advise consumers of any limitations of our health web site as a
source of health care services. In
particular, we will state that online health services and health information
content cannot replace a health professional-patient relationship, and that
consumers should always consult with a professional for diagnosis and
treatment of their specific health problems.
14. Mechanism for Consumer Feedback
We will make it easy for consumers to provide us with feedback or
complaints concerning our health web sites.
* * *
Founding members of Hi-Ethics intend to implement these principles
within six months. Contracts with a third party and a health web site in
effect when these principles are adopted need not be amended, if the health
web site has a good faith belief that the contract is in compliance with the
principles set forth herein.
HI-ETHICS GLOSSARY
For
purposes
of the Hi-Ethics Principles --
- AGGREGATE DATA means personal information or
non-personal individual information collected from a group of users that has
been processed so that it can no longer be used to identify a single, unique
individual.
- CO-BRANDING refers to the joint branding of a
web page or section of a consumer health web site between two or more
corporate entities or individuals. Co-branding may involve the joint operation
of services, health information content or products that appear on a consumer
health web site.
- HEALTH INFORMATION CONTENT includes information
to help consumers stay well, prevent and manage disease, and make decisions
related to health and health care, including information for making decisions
about health-related products and health services. It may be in the form
of data, text, graphics, audio or video, and may involve special software or
hardware and programming enhancements that support interactivity.
Health information content includes both materials authored by third parties
(whether scholarly works by scientists and clinicians or interpretive articles
prepared for consumers), as well as materials created specifically for use on
a health web site.
-
HEALTH-RELATED PERSONAL INFORMATION refers to
personal information that is associated with health issues, categories,
questions, and facts obtained as a result of the individual's responses and
activities on a health web site.
-
INTERNET HEALTH SERVICES means the full range of
services and activities available on a consumer health web site.
Examples include the sale of health care products, delivery of health care
services and health information, specialized health information searches,
self-assessment tools and activities, bulletin boards, chat rooms with and
without participation by health professionals, and opportunities for
relationships and communication with health care professionals and health
plans.
-
NON-PERSONAL INDIVIDUAL INFORMATION does not include
any information that would meet the definition of personal information
(below), but may include information about a specific individual's
characteristics, preferences, interests, experiences, and activities disclosed
by the individual to the health web site or obtained through the individual's
use of the health web site.
-
OPERATE refers to the degree of control a corporation
or individual has over the operations of a consumer health web site. A
corporation or individual operates a consumer health web site if the
corporation or individual is primarily responsible for the material that
appears on the site, including, but not limited to, advertising, health
information content, services and products.
-
OPT-IN means an affirmative ability for a consumer to
accept terms and conditions.
-
PERSONAL INFORMATION means any individually
identifiable information about an individual collected online, including a
first and last name, a home or other physical address, including street name
and name of a city or town, an E-mail address, a telephone number, a Social
Security number, or any other identifier that may permit the physical or
online contacting of a specific individual.
-
SELF-ASSESSMENT TOOLS refers to online forms that
allow an individual to supply personal information and health-related
information that cause interactive software programming using medical
knowledge to reach conclusions that may be relevant to optimizing health care
decisions or possible health outcomes.
-
UNRELATED
THIRD PARTY refers to a corporate entity or individual who acts on its own
behalf and in its own interest and to carry out a purpose other than that for
which the individual accessed the consumer health web site.
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