1. Introduction
Exclusion Screening, LLC (“Exclusion Screening,” “we,” “us,” or “our”) is committed to protecting the privacy of individuals who visit our website, use our SAFER Plus™ platform, or otherwise interact with our services. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and what rights you have regarding your data.
By using our website at http://www.exclusionscreening.com or our services, you agree to the terms of this Privacy Policy.
2. Who We Are
Exclusion Screening, LLC provides healthcare compliance solutions, including OIG exclusion screening, SAM database monitoring, state Medicaid exclusion list screening, and compliance hotline services. Our SAFER Plus™ platform enables healthcare organizations to screen employees, contractors, and vendors against federal and state exclusion databases.
For questions about this Privacy Policy or your data, contact us at:
- Email: support@exclusionscreening.com
- Phone: (800) 561-0798
- Address: 2121 Wisconsin Avenue NW, Suite 200, Washington DC 20007
3. What Personal Data We Collect
3.1 Information You Provide Directly
When you create an account, contact us, or use our services, we may collect:
- Full name and job title
- Business email address and phone number
- Organization name and address
- Login credentials (passwords are encrypted and never stored in plain text)
- Payment and billing information (processed securely via third-party payment processors)
- Communications you send us, including support requests and complaints
3.2 Screening Data
As part of providing our exclusion screening services, our platform processes personal data about individuals being screened (employees, contractors, vendors) on behalf of our clients. This includes:
- Full name and date of birth
- National Provider Identifier (NPI) or other professional identifiers
- Social Security Number (where required for screening purposes)
- Screening results and compliance records
This data is processed on behalf of our clients in accordance with our client agreements.
3.3 Automatically Collected Data
When you visit our website, we automatically collect certain technical data, including:
- IP address and browser type
- Pages visited and time spent on site
- Referring URLs and search terms
- Cookie and tracking data (see Section 7)
4. How We Use Your Data
We use the personal data we collect for the following purposes:
- To provide and manage our exclusion screening and compliance services
- To operate and maintain your account on the SAFER Plus™ platform
- To process payments and send billing communications
- To respond to your inquiries, support requests, and complaints
- To send service-related notifications and updates
- To improve our website, platform, and services
- To comply with legal obligations and regulatory requirements
- To detect and prevent fraud or misuse of our services
We do not sell your personal data to third parties. We do not use your data for automated decision-making or profiling.
5. Legal Basis for Processing
Where applicable under GDPR or other privacy laws, we process personal data on the following legal bases:
- Contract: Processing necessary to fulfill our services under a client agreement
- Legal Obligation: Processing required to comply with applicable laws and regulations
- Legitimate Interests: Processing for fraud prevention, security, and service improvement
- Consent: Where you have given explicit consent (e.g., marketing communications)
6. Who We Share Your Data With
We do not sell your personal data. We may share your data with the following categories of third parties:
- Service Providers: Hosting, IT infrastructure, payment processing, and analytics providers who process data on our behalf under strict data processing agreements
- Government Databases: We access publicly available federal and state exclusion databases (OIG, SAM, state Medicaid lists) as part of our screening services
- Legal and Regulatory Authorities: Where required by law, court order, or regulatory requirement
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity
All third-party service providers are contractually required to protect your data and use it only for the purposes we specify.
7. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your experience and analyze site usage. We use the following types of cookies:
- Essential Cookies: Required for the website and platform to function correctly
- Analytics Cookies: Used to understand how visitors interact with our site (e.g., Google Analytics)
- Marketing Cookies: Used to deliver relevant content and measure campaign effectiveness
You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of our website.
8. How Long We Retain Your Data
We retain personal data only for as long as necessary to fulfill the purposes described in this policy, or as required by law:
- Account data: Retained for the duration of your contract and for up to 7 years thereafter for legal and compliance purposes
- Screening records: Retained in accordance with client agreements and applicable healthcare compliance regulations
- Website usage data: Retained for up to 24 months
- Support and communications: Retained for up to 3 years
When data is no longer needed, we securely delete or anonymize it.
9. Data Security
We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration, or disclosure, including:
- Encryption of data in transit (TLS) and at rest
- Access controls and role-based permissions
- Regular security assessments and monitoring
- Secure secrets management for API keys and credentials
- Employee training on data protection practices
In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected individuals and relevant authorities as required by applicable law.
10. Your Privacy Rights
Depending on your location, you may have the following rights regarding your personal data:
- Right to Access: Request a copy of the personal data we hold about you
- Right to Correction: Request that we correct inaccurate or incomplete data
- Right to Deletion: Request that we delete your personal data (subject to legal retention requirements)
- Right to Portability: Request your data in a structured, machine-readable format
- Right to Object: Object to certain types of processing, including direct marketing
- Right to Restrict Processing: Request that we limit how we use your data
- Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time
To exercise any of these rights, please submit a request using our Data Deletion & Privacy Request Form.
We will respond within 5 business days and complete your request within 30 days.
11. California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt out of the sale of your personal information.
We do not sell personal information. To exercise your California privacy rights, please contact us at support@exclusionscreening.com or use our Data Deletion Request Form.
12. Children’s Privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us immediately at support@exclusionscreening.com.
13. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal data.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last Updated” date at the top of this page and, where appropriate, notify you by email or through our platform. Your continued use of our services after any changes constitutes your acceptance of the updated policy.
15. Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:
- Email: support@exclusionscreening.com
- Phone: (800) 561-0798
- Mail: Exclusion Screening, LLC, 2121 Wisconsin Avenue NW, Suite 200, Washington DC 20007