MDGuidelines Privacy Notice to Eligible Providers

I. Background and Authority

Pursuant to the California Information Practices Act of 1977 (Civ. Code, § 1798.17), this notice explains how personal information about you, an Authorized User of the MTUS MDGUIDELINES website ("MDGuidelines" or "Website") pursuant to the 2018 contract ("Contract") between the State of California Department of Industrial Relations Division of Workers' Compensation ("DIR") and Reed Group, LLC. of Lincolnshire Colorado ("ReedGroup"), will be collected, used and maintained by DIR or ReedGroup.

DIR entered into the Contract pursuant to Labor Code section 133, and with the goal of facilitating use of the evidence-based medical treatment guidelines and drug formulary mandated by Labor Code section 5307.27. The Contract specifies that two groups of individuals shall have access to MDGuidelines: certain DIR employees ("Eligible DIR Employees"), and specific kinds of providers defined under the Labor Code who either treat injured workers, or who are involved in the review or medical-legal evaluation of such treatment ("Eligible Providers"), known collectively as Authorized Users. This Privacy Notice pertains to Eligible Providers.

II. Personal Information of Authorized Users

ReedGroup will collect and report to DIR two types of information about Eligible Providers: individually-identifiable information necessary to authenticate an Eligible Provider as an Authorized User, and anonymous data about Eligible Provider's Website use.

A. Individually Identifiable Information

Individual providers must authenticate their identity and demonstrate eligibility for DIR-provided access to MDGuidelines by registering to use MDGuidelines. To register, an individual must provide the following:

• Last name, First name
• Email address
• Name of employer or client
• National Provider Identification Number
• Physician or Health Provider License Number(s)
• State(s) that issued license(s)
• Location of practice: City, State
• Specialty(ies)
• Reasons for accessing MDGuidelines [patient treatment, evaluation, other administration]

Individuals who do not provide all of the requested information will not be authenticated, and will be unable to use MDGuidelines pursuant to the Contract.

ReedGroup will confirm the above information against data received from California's licensing boards, and then report the confirmed Authorized Users' profiles to DIR. These records of authenticated Eligible Providers are designated confidential information under the Information Practices Act.

DIR will use individually-identifiable information for general administrative purposes, such as evaluating the efficiency of the Contract; and doing research related to the California workers' compensation system. Please note that as specified in DIR's Data Collection and Use Policy, available at https://www.dir.ca.gov/od_pub/privacy.html, DIR may use this data for general law enforcement purposes also.

B. De-Identified Data about Eligible Providers' Use of MDGuidelines

In addition to providing DIR with the profile of authenticated, registered Authorized Users who are Eligible Providers, ReedGroup will report de-identified, electronically-collected information about Eligible Providers' use of the Website to DIR. ReedGroup will not include the identity of, or as defined at Government Code section 11015.5, personal information about the Eligible Providers in that data.

ReedGroup will employ cookies to collect this data. These cookies will reside in the browser used by an Eligible Provider to access MDGuidelines unless and until the Eligible Provider manually deletes the cookies by using the browser's privacy and security tools found under the settings tab.

Such de-identified usage information will include, for example, which pages of the Website are visited most frequently, which electronic tools are utilized, etc. This information will not be stored by ReedGroup or reported to DIR in a format that identifies individuals. Rather, ReedGroup will de-identify usage data before storing it, or reporting it to DIR; individually-identifiable elements will be destroyed. ReedGroup is prohibited by law from selling or further distributing the information it collects electronically about Eligible Providers' use of the Website. Any electronically-collected information about an Eligible Provider that identifies a unique Eligible Provider under Government Code section 11015.5 (for example, name or network location or identity), and has not yet been de-identified is exempt from disclosure under California's Public Records Act (Govt. Code, §§ 11015.5, subds. (a)(7) and (d)(1) and Govt. Code § 6250 et seq.).

ReedGroup may use this de-identified data for purposes of improving MDGuidelines, developing marketing materials, or enhancing its MDGuidelines user training programs.

DIR may use this de-identified data to assess the effectiveness of the Contract, including ReedGroup's outreach and training of Eligible Providers.

III. Your Rights and Further Information

The Information Practices Act gives individuals certain rights to inspect, obtain copies of, and request correction of records about them maintained by a state agency. (Civ. Code, §§ 1798.3, and1798.30-1798.44). You may find a copy of DIR's Privacy Policy at https://www.dir.ca.gov/od_pub/privacy.html. The Government Code gives you the right to opt-out of the electronic collection of personal information about your use of the Website. (Gov. Code, § 11015.5). If you require access to your record related to MDGuidelines, please contact

State of California Department of Industrial Relations
Division of Workers' Compensation
Attn: Dr. R. Meister
P.O. Box 70823
Oakland, CA 94612
(800) 794-6000

Or DWC@dir.ca.gov