Privacy Policy
This privacy statement applies to PCOM’s websites, applications and IT (Information
Technology) services, domains (pcom.edu), and governs and explains PCOM’s data collection
and usage.
Privacy Statement
Philadelphia College of Osteopathic Medicine (“PCOM”) is committed to respecting the
privacy, intellectual freedom, and freedom of expression of its students, faculty,
staff, and other members of the PCOM community. These values are fundamental to PCOM’s
academic mission and institutional culture.
At the same time, there are limited circumstances in which authorized individuals
other than the account holder may need to access computers, electronic files, or data
associated with the use of PCOM’s information technology systems and networks. Such
access may be necessary to protect the confidentiality, integrity, and availability
of PCOM systems and information; ensure the security of user and institutional data;
maintain compliance with applicable laws, regulations, and PCOM policies; support
institutionally approved research through the use of appropriately de-identified data;
or respond to lawful requests, subpoenas, or other legal or regulatory obligations.
PCOM seeks to balance individual privacy interests with its responsibility to safeguard
PCOM operations, protect its community, and comply with legal requirements. Access
to systems or data, when authorized, is limited to what is reasonably necessary to
fulfill these purposes and is conducted in accordance with applicable policies and
procedures.
This privacy statement applies to PCOM’s websites, applications and IT (Information
Technology) services, domains (pcom.edu), and governs and explains PCOM’s data collection
and usage. Information collected by PCOM will be used only as outlined in this privacy
statement. By using this website, you consent to the data practices described in this
statement.
Other colleges and campuses at PCOM may collect and use information in diverse ways.
Therefore, when visiting and using other PCOM websites and applications, please review
the privacy notices for the sites being visited. PCOM is not responsible for the content
of other websites or for the privacy practices of websites outside the scope of this
notice.
No data transmission over the internet or website can be guaranteed to be secure from
intrusion. However, we maintain commercially reasonable physical, electronic and procedural
safeguards to protect your personal information in accordance with data protection
legislative requirements.
Information Gathering
PCOM collects two types of information from users.
- Information anonymously collected upon a user’s visit to PCOM websites.
- Information provided by the user to receive requested information and/or services.
Information Collection and Use
PCOM may collect information about how users access and use its websites, networks,
and related resources. The information collected on PCOM sites or from use of PCOM
systems may include the computer address used, the internet domain, the website the
user came from or goes to, measurements of use, types of content used, and other details.
This data is used for website and network management, to improve website content,
improve user experience (including directing users to specific types of content),
and for security purposes. Cookies and similar technology may be used to facilitate
the navigation of this site.
Anonymously Collected Information
When you view pages on PCOM sites, the web server automatically collects certain technical
information from your computer or device and about your connection (see list below).
PCOM uses this information solely for internal purposes, such as to see what pages
are most frequently visited as well as what applications and functions are utilized
to improve our sites and application support. Additionally, PCOM uses Google’s Universal
Analytics, a web metrics service, to collect information automatically upon a user’s
visit. For more information regarding Universal Analytics, see Google’s privacy policy.
Additional web metrics and analytics services may be used on other PCOM websites.
Our server(s) and/or site(s) collect the following information.
- The domain name from which you visit our site
- Internet protocol (IP) address
- Internet service provider
- Aggregate information on pages visited
- The referring website
- The date and time of visit
- The duration of visit
- Your browser types and versions
- Your screen resolution
- Information about your device and operating system
- Aggregate information collected by Google Analytics
- Application access through PCOM’s portal and utilization
Some technical information is retained in aggregate for up to 48 months.
Information Provided by the User
- We may ask you to provide information voluntarily (through forms or other manual input)
to make products and services available to you, to maintain and manage our relationship
with you, to provide associated services to you, or to better understand and serve
your needs. This information will be retained if you continue to maintain a relationship
with us. You are providing this information voluntarily. However, not providing the
requested information (or subsequently asking that the data be removed) may affect
our ability to deliver the products or service for which the information is needed.
Providing the requested information indicates your consent to the collection, use
and disclosure of this information as described in this statement. Information we
may actively collect could include information volunteered by the visitor, such as
interests, preferences, survey information and/or site registrations. This information
could be used to customize the content of our site specific to your inquiries.
- The email addresses of those who communicate with us via email
- The email addresses of those who post to our chat areas
- Name
- Address
- Telephone number
- Information volunteered by the visitor, such as preferences, survey
- information and/or site registrations
Information Usage
This information may be used for the following reasons.
- Internal review
- Content and/or page layout customization
- Used by us to contact visitors for marketing purposes
Information Used For Contact
If you supply us with your postal/mailing address you may receive periodic mailings
from us with information on new products and services or upcoming events.
If you do not want to receive such mailings or would like to be added to our “do not
share” list, please email us at dataprivacy@pcom.edu.
Information Sharing
We may share aggregate, non-personally identifiable information with other entities
or organizations. We do not share any personally identifiable information (PII) with
other entities or organizations, except when legally required to do so, at the request
of governmental authorities, to verify or enforce compliance with the policies governing
our website and applicable laws, or to protect against misuse or unauthorized use
of our website.
Use of Cookies
A cookie is a small text file that a website saves on your computer or mobile device
when you visit the site. It enables the website to remember your actions and preferences
over time, so you do not have to reenter them whenever you come back to the site or
browse from one page to another. For the purposes of this privacy statement, a cookie
may also refer to an
anonymous identifier (a random string of characters that is used for the same purposes
as a cookie on certain platforms, including some mobile devices) when cookie technology
is not available. To customize the information and services offered to you, PCOM’s
site uses cookies to:
- customize web page content based on visitors’ browser type or other information that
the visitor, or their browser, sends;
- record aggregate information collected by Google Universal Analytics;
- allow users to comment on articles;
- display PCOM alert messages;
- provide certain ‘like’ or ‘share’ buttons;
- enable logging in to certain sites, including completing the process of applying to
PCOM; and
- anonymously gather statistics on content review
If you prefer not to receive cookies, you may configure your browser not to accept
them at all, or to notify and require approval before accepting new cookies. Some
webpages/sites may not function properly if the cookies are turned off or you may
have to provide the same information each time you visit those pages.
In compliance with the General Data Protection Regulation, individuals within the
EU will automatically receive a notification as you enter a site, asking for consent
to capture this cookie data. If you withdraw your consent later, use your browser’s
settings to review and delete cookies stored by PCOM’s websites.
Use of Third-Party Services
PCOM websites use third-party websites (e.g., Google Analytics, Facebook and X) to
help enhance features, provide a robust and personalized user experience and analyze
how users use the sites. The third-party tools typically utilize cookies but may also
use pixel gifs or beacons. Cookies, pixel tags and beacons are used to obtain information
about the device being used to view a webpage, including the time spent on the site,
the user’s operating system and browser type, demographic data, and similar information.
The information generated via these cookies about your use of PCOM websites is transmitted
to these third-party tools. This information is then used to evaluate visitors’ use
of the websites and to compile statistical reports on activity from our websites.
We may use Google Analytics to aggregate and track non-identifiable visitor information
for the following business purposes: re-marketing across devices with Google Analytics,
Google Display Network Impression Reporting, DoubleClick (Google Ads), Google Analytics
Demographics, Google Analytics Advertising Features and Interest Reporting.
If you would like to opt-out of Google Analytics tracking, Google has provided a plugin
for most browsers that enables this functionality. Google Analytics also provides
you with the ability to modify and delete the information that Google tracks for re-marketing
purposes. You can also disable collection of any demographic data on that page. Also,
you can modify and delete the information that Google tracks for re-marketing purposes
by visiting Google’s ad settings page. You also have the option of disabling collection
of any demographic data on that page.
In addition, PCOM websites may contain links and integrate with other websites and
applications owned by third parties as a convenience to the user. These websites and
applications operate independently of PCOM and have their own privacy policies. Some
cookies also can carry all or parts of the information stored within the file generated
on PCOM’s website to other websites that the user may visit or to third parties. If
a user decides to use these third-party links, they will leave the PCOM websites.
PCOM is not responsible for the privacy practices or the content of such third-party
websites and does not make any representations or endorsements about them. If a user
decides to leave PCOM’s websites and access any third-party site, it will be at the
user’s own risk.
Disclosure of Information
Other than sharing your information with other appropriate PCOM personnel, business
units and contracted partners to ensure the quality, functionality and security of
our website, or to manage your relationship with us, we will not disclose personally
identifiable information about your use of the site except under the following circumstances.
- With your prior written (including email) consent
- When we have given you clear notice, we will disclose the information you voluntarily
provide
- With appropriate external parties, such as law enforcement agencies, to investigate
and respond to suspected violations of law or PCOM policy.
Any such disclosures shall comply with all applicable laws and PCOM policies.
Children and Privacy
PCOM is concerned about protecting children/minor’s privacy. A child/minor is anyone
under the age of 18. However, this excludes enrolled PCOM students under the age of
18; these students are subject to all applicable PCOM policies, including the Student
Conduct Code.
As a nonprofit higher education institution, we operate under the assumption that
all visitors to our websites are over the age of 13. We do not knowingly collect personally
identifiable information from children who visit our website. If a visitor known to
be a child (that is an individual under the age of 13, as defined by the Children’s
Online Privacy Protection Act) sends an email to dataprivacy@pcom.edu, we only will use it to respond to the writer and not to create profiles or otherwise
retain the information.
PCOM does provide youth programs, including programs that utilize online software
programs and third-party applications, and in certain circumstances, it is required
to collect and use personal information from parents, guardians or participants for
the purpose of providing, operating, improving and promoting the programs. During
the registration for such programs, PCOM will provide notice to and obtain the consent
of the parents or guardians of the student regarding any additional information collection
practices specific to the online program. Any information is collected solely for
the purpose of offering the program, and not for advertising the services of the third
party or other commercial purposes.
Security
Due to the rapidly evolving nature of information technologies, no transmission of
data over the internet can be completely secure. While we are committed to protecting
the privacy of our visitors, we cannot guarantee the security of any information that
you transmit to PCOM websites and applications, and you do so at your own risk. However,
once we receive your information, we use reasonable safeguards consistent with prevailing
industry standards and commensurate with the sensitivity of the data being stored
to maintain the security of that information on our systems.
In addition, we comply with all applicable federal, state and local laws regarding
the privacy and security of information. We have appropriate security measures in
place in our physical facilities to protect against the loss, misuse or alteration
of collected information.
Desk and Room Scanning During Proctoring
Students should not be required to physically turn their computers or webcams to conduct
visual scans of their surroundings when taking proctored exams online. The discontinuation
of the practice of room scanning at PCOM will improve the student experience during
virtual assessments. As a college, we strive for academic integrity across all courses,
and have offered artificial intelligence (AI) proctoring software to support this
goal. While proctoring can still be one tool to promote academic integrity, faculty
members should carefully consider the necessity of using the software before implementing
it in their courses and review other options to improve assessments.
Information Correction and Deletion
If you believe that the information we have about you is incorrect, you are welcome
to contact us so we can update it and keep your data accurate. Any data no longer
needed for the purposes specified in this notification will be deleted. For privacy
reasons, you have the right to ask for certain personal information relating to you
to be removed. Please direct all requests to the chief privacy officer or data processing
officer via email at dataprivacy@pcom.edu.
Policies Governing Use of PCOM’s Websites
PCOM’s policies enable it to function efficiently and appropriately. By using this
website, PCOM’s network or related resources (PCOM systems), you agree to abide by
any and all applicable PCOM policies.
Legal and Regulatory Obligations
Please be aware that PCOM has various legal and regulatory obligations to disclose
many types of information, as well as operational reasons for doing so. Unless specifically
protected (e.g., FERPA-protected student information, HIPAA-protected health information),
PCOM may disclose information obtained through your use of PCOM’s systems for school
business purposes in accordance with governing law.
Privacy Statement Changes
Because internet technologies continue to evolve rapidly, PCOM may make appropriate
changes to this notice in the future. Any such changes will be consistent with our
commitment to respecting privacy. This privacy statement will be updated as necessary.
Contact Information
If you have questions or concerns about PCOM sites, the use of PCOM systems as they
apply to this privacy statement, or general questions or concerns about privacy or
information technology policy at PCOM, please contact the chief privacy officer via
email at dataprivacy@pcom.edu.