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The Quinlan Companies Privacy and Security Statement

Security and privacy are priorities at The Quinlan Companies. We are committed to maintaining the highest level of confidentiality and integrity when interacting with our customers. The following document outlines how The Quinlan Companies uses and secures data provided by client users via the QuinlanVault application (www.quinlanvault.com.) This document does not constitute a contract or create legal rights or modify or amend any agreements The Quinlan Companies has with its clients. Please review periodically, as The Quinlan Companies is dedicated to enhancing its privacy and security policies consistent with the highest industry standards as technology improves and regulations change.

Password Protection

Usage of QuinlanVault is restricted to clients and employees of The Quinlan Companies. The Quinlan Companies requires users of QuinlanVault to enter a unique user name and password. User names and passwords are assigned and administered by the Information Technology Manager at The Quinlan Companies following a consultation and application tutorial. Passwords ensure that access to QuinlanVault is limited to those with permission from The Quinlan Companies management team. Any request pertaining to the issue of new user names and passwords, deletion of current user names and passwords, or reissue of existing passwords should be addressed to Quinlan management. Client users are not able to change user names and passwords via the QuinlanVault interface.

Internet Security Measures

Any information submitted via QuinlanVault is scrambled with 128-bit encryption, as QuinlanVault is a Thawte (www.thawte.com) approved secure site. The encryption technology utilized by QuinlanVault, called Secure Socket Layers (SSL) protects information users submit or receive through this site. In addition, any information that users send to QuinlanVault is held in a secured environment. There are three types of QuinlanVault users:

Client users:

Client users are clients of The Quinlan Companies that have been issued a user name and password and have access to the requesting and reporting functionality of QuinlanVault that pertains to client-specific record inventories. There may be multiple unique users accessing data from one particular client.

Support Services user:

Support Service users are employees of The Quinlan Companies and are responsible for fulfilling client record requests and maintaining the Quinlan record library. Support Service users have access to requesting, data entry, data modification and inventory reporting functionality for all clients with QuinlanVault record inventories. Support Service users have access to limited client data and functionality.

Super user:

Super users have access to all functionality and data within QuinlanVault. Super user access is limited to members of The Quinlan Companies management team and contracted information technology consultants, the developers who developed and maintain the QuinlanVault application, and individuals at the ISP that hosts the QuinlanVault application.

Firewall and Backup

The Quinlan Companies uses firewalls to help limit entry by anyone without proper authorization. A firewall is a security mechanism that regulates the data going in and out of a network. It utilizes specialized hardware and software which acts as a shield against data going in or out of a network. It checks to make sure that communications only occur between approved individuals and that the communication is in the proper protocol. The information contained within QuinlanVault is backed up continually in real time to guard against a hardware (hard drive) failure. Additionally, the QuinlanVault data is backed up to tape daily. This secure backup ensures that the data contained within QuinlanVault is always able to be restored should the QuinlanVault data be compromised in any way.

Cookies

Cookies are small blocks of data that are placed on your computer and that are sent by your web browser to our computer when you visit QuinlanVault. QuinlanVault uses cookies to collect Quinlan issued user name and password information to identify the user during his or her session using QuinlanVault. No personal information is collected. This basic information is then linked to user information within QuinlanVault to allow the application it's user-specific functionality. Linked user information includes:

It is necessary for users of QuinlanVault to accept these cookies, which remain on the user's computer until log out. QuinlanVault stores cookies on your computer until you log off of the QuinlanVault application. Please note that closing your browser or visiting another web site using the same browser without first logging off of QuinlanVault will result in your cookie information remaining accessible to other users. Given the sensitive nature of the medical information stored within QuinlanVault, users are strongly encouraged to log out of QuinlanVault immediately upon completion of the session.

Usage Logs

In order to monitor and track access of medical record information as required by HIPAA, QuinlanVault maintains a log of user activity. These logs are neither stored on the user's computer nor collect personal information aside from the Quinlan issued user name and password of each user. Usage information is a vital aspect of the QuinlanVault reporting functionality.

HIPAA Compliance

QuinlanVault is HIPAA (Health Insurance Portability and Accountability Act) compliant. The Quinlan Companies is dedicated to ensuring that the QuinlanVault application is HIPAA compliant as the HIPAA regulations change into the future. To obtain more information about HIPAA regulations, please refer to the Department of Health and Human Services web site (www.hhs.gov).

Sharing Information Outside of The Quinlan Companies

The Quinlan Companies does not share or sell client information with outside individuals or entities unless required for law enforcement or statute. Information provided or derived via the QuinlanVault, such as client contact and record inventory information, is used by employees of The Quinlan Companies for the purpose of fulfilling the requests of the client. Information provided by the client via QuinlanVault may also be used for the following reasons:

Third-Party Web Sites

This QuinlanVault web site may contain links to third-party sites that you may find useful. These sites may have their own privacy policies. You should review the privacy policy of any Web site before you provide personal or confidential information.

How Clients Can Ensure Secure Interaction with QuinlanVault

Last Updated November, 2009

www.quinlanvault.com
A Thawte: www.thawte.com approved secure site