PRIVACY POLICY FOR HIRECULTURE WEB SITE

Welcome to the hireCulture web site ("site"), developed by the Massachusetts Cultural Council ("MCC," "We," "Us," "Our"). This policy covers how We use and treat personal information collected and received through use of this web site by individuals who are searching for employment ("Job Seeker" or "User") and companies that provide employment, internship, and/or volunteer listings ("Company," "User," or "Job Poster"). This privacy policy is intended to provide Job Seekers and Companies with information pertaining to this site's privacy practices, including:

1. What personally identifiable information, if any, is collected from Users through their use of this site and how this is done;

2. How Users' information will be used;

3. With whom the Users' information may be shared or disseminated, and under what circumstances this can occur;

4. The type of security procedures, if any, that are in place to protect against the loss, misuse, alteration, or unintentional destruction of Users' information;

5. How Users can access and correct any inaccuracies in the information collected about them, when appropriate; and

6. Who to contact if Users have any questions regarding this Privacy Policy and use of their information.

Based upon this Policy, Users can, in some cases, make an informed choice as to the information they wish to share with Us. This Policy does not apply to the privacy practices of other state agencies or their employees. Web sites operated by other agencies may have different privacy practices in effect and any inquiries regarding these other practices must be directed to the appropriate agency. We will not answer any inquiries about another agency's privacy policy or practices. Also, this Policy only applies to this specific site. Other sites operated by or associated with the MCC may have different privacy policies in effect. Please consult the appropriate policy when using other affiliated sites.

Also, this Policy only applies to this site and to those sites directly associated with Us which have explicitly incorporated Our Policy. Other non-associated sites may have different privacy policies in effect. Please consult the appropriate policy when using other sites if You have any questions or concerns. This Policy does not apply to any other information collection and/or dissemination practices that We may utilize outside of this site. Also, to the extent that Our site contains any content which conflicts with the terms of this Policy, this Policy shall control.

What Information We Collect and How We Do It
Information can generally be collected in two ways: (1) Information that is knowingly and voluntarily input into the system directly by the User in response to particular prompts or fields; and (2) information that is collected automatically. This site does not require Job Seekers to input any personally identifiable information in response to particular prompts or fields before using it. Companies, however, are required to provide some information voluntarily. Also, this site does automatically collect some information when Users use it. This is explained in more detail below.

Some information can be "personally identifiable." We use the term "personally identifiable information" to mean any type of information which could be utilized to identify or be readily associated with a particular individual using this site. Examples of personally identifiable information include, but are not limited to, a User's name, address, telephone number, and e-mail address, or any combination thereof. Pursuant to the Fair Information Practices Act, Chapter 66A, Section 2(l), We do not collect or maintain more personally identifiable information than is reasonably necessary for the performance of the MCC's statutory functions or for the operation of this site. Additional protection may also be found in Executive Order Number 412. With respect to the operation of this site, We do NOT at this time collect any personally identifiable information from Job Seekers.

If, however, the User is a Company, We do require the Company to provide basic information when using the site. For example, in order for a Company to provide job postings, it will be required to provide Us information upon registration such as its name, phone number, address, and geographic location. This is not personally identifiable information per se, as no individual is being readily associated with that particular Company. A Company is required to provide the name of a contact person at registration, but this contact information is for MCC's internal use only. In this instance, the Company is required to obtain the consent of its contact person prior to listing any job information. In some instances, though, a Company may want to provide a particular contact person to the Job Seeker to receive inquiries about the job listing. In this instance, that individual could be readily associated with the particular Company using the site. This would be the extent of the personally identifiable information known about that person to a Job Seeker.

The transmission of an e-mail voluntarily initiated by a User to Us can transmit personally identifiable information about the User. For example, a User's e-mail address can be considered personally identifiable information in some instances. If a User includes his/her name, telephone number, and other information in the body of the e-mail, this information is also personally identifiable. A User should not send personally identifiable information through this web site via unencrypted e-mail, particularly information that the User deems to be sensitive or confidential. Also, as described herein, this information could be disclosed in certain circumstances.

The automatic collection of information refers to information collected from a User that does not require the User to knowingly and intentionally provide information in response to particular fields or prompts. For example, this site uses "cookies." A cookie is a small text file automatically placed on a User's web browser that is used to recognize Users who have visited the site previously. In general, these cookies are either persistent and may reside on a User's computer for several months after a User last accessed the site (or until the User deletes or otherwise disposes of them), or on a temporary basis. For example, a site may use temporary cookies called "session cookies," which are stored for a single user session with the site and are deleted as soon as the user's browser is shut down. Presently, this site uses session cookies for both Job Seekers and Companies. We do not use persistent cookies at this time.

We also automatically collect a User's "internet protocol" ("IP") address. An IP address is a unique series of numbers that identifies each computer connected to the internet. An IP address can be used to provide information such as the date and time of a User's visit, the availability of certain requested files, the popularity of various web site functions, and the amount of information transmitted to each User from a site. Presently, We use a User's IP address to address the frequency of visits to this site and to determine the frequency with which certain pages and functions of the site are accessed. This will allow Us to improve the site's functionality and ease of use. As a particular computer is identified, rather than identifying a particular User, no personally identifiable information is disclosed. We will not routinely attempt to match a User's particular IP address to any personally identifiable information that a User may provide to Us on its own, except in certain situations. For example, in instances where We, in Our sole discretion, suspect or determine that the site is being used for any unacceptable, inappropriate, or illegal purposes, information relating to a User's use of this site may be disclosed to other parties as We deem appropriate. Such information may also be disclosed pursuant to any authorized law enforcement investigation, regardless of whether it was initiated by Us or by another party.

How We Use Your Information
As stated earlier, pursuant to the Fair Information Practices Act, M.G.L. Chapter 66A, Section 2(l) and Executive Order Number 412, We do not collect or maintain more personally identifiable information than is reasonably necessary for the performance of the MCC's statutory functions and/or for the operation of this site. All of the information collected at this site may be stored in Our database for an indefinite period of time. We may supplement, aggregate, or combine the information collected at this site with information from Our own database and from other MCC sources to produce reports for the legislature consistent with Our statutory mandate and to fulfill any requests made pursuant to the Massachusetts Public Records Law, M.G.L. Chapter 66. We may also do so in some instances when providing information to certain third party service providers or vendors, as set forth below.

Dissemination of Your Personally Identifiable Information
As noted above, We do not collect any personally identifiable information from Users on this site except what a User may provide to Us via e-mail or the contact information provided by a Company. We do not sell or license any personally identifiable or other information We collect from a User when using this site to any party. However, once personally identifiable information is collected through a User's use of this site, its dissemination becomes subject to certain laws and policies, including, but not limited to, the Massachusetts Public Records Law, M.G.L. Chapter 66; the Fair Information Practices Act, M.G.L. Chapter 66A; and Executive Order Number 412. Consequently, any User's personally identifiable information sent to Us could be disseminated to the public in response to an official public records request. In addition, any of the information that is submitted by, or collected from a User can be disclosed to employees or officials of, or those under contract to, the Commonwealth of Massachusetts who have a "need to know" such information for purposes of fulfilling their job responsibilities, legal obligations, or for rendering assistance to a User. In some instances, We may provide the information submitted by a User via e-mail to the person or company that is the subject of the User's inquiry or to a government agency responsible for the matters referred to in that communication.

Web Site Security
This is NOT a secure site. As We do not collect any personally identifiable information except for Job Poster contact information, We have not employed any security measures to protect data. We have not implemented any security protocols regarding the access, use, encryption, disclosure, or authentication of any information that is available on this site or that a User makes available to Us.

Accessing and Correcting Your Information
As We do not collect any personally identifiable information from Job Seekers, We do not provide access to a Job Seeker to correct any information that he/she deems to be inaccurate, incomplete, or out-of-date. If the User is a Company, however, We do provide access to the Company to correct any inaccurate, incomplete, or out-of-date information which the Company may have provided to Us previously. If, however, a Job Seeker or Company sends e-mail to Us, We may provide access to this e-mail under certain circumstances. In general, the Massachusetts Public Records Law, M.G.L. Chapter 66 and the Fair Information Practices Act, M.G.L. Chapter 66A provides certain rights to Users when a User wants to obtain their information in Our records.

Children's Information
We do not actively market, target, or direct Our efforts to, or knowingly collect personally identifiable information from, children under the age of thirteen (13) years.

Third Party Service Providers and Vendors
MCC contracts with a third party service provider, RackSpace, to assist Us in hosting this site and managing certain functions in its operation. We only provide third party service providers with Our information so that it may perform its services in operating this site. We do not purposely or knowingly disclose a User's personally identifiable information to third party service providers. If a User has any questions about Rackspace's privacy or other business practices, please review its privacy policy at www.rackspace.com. We reserve the right to add or change service providers or vendors at any time in Our sole discretion.

Policy Revisions
We have the right, at any time and without notice, to modify the terms of this Policy. Any revisions made to this Policy will take effect immediately upon its posting to Our site. Any information collected under the current Policy will remain subject to those terms and conditions. Your access to or use of the site after the date such amended Policy is posted or added shall be deemed to constitute Your acceptance of the amended Policy. No modification made by You shall be binding upon Us unless it is made in writing and signed by Us.

Links to Other Web Sites
This site may contain hypertext link to other websites. We are not responsible or liable for the content, transmissions, or privacy practices of such sites. Any questions that You may have regarding another site's content, transmissions, or privacy practices must be directed to the appropriate party at that site. If the link is provided by a user or other third party in those areas of Our site where outside content can be posted, You may also direct Your questions to the party that provided the link, if possible.

Contact Information
For any questions about this privacy policy or Our information collection and dissemination practices, please contact dawn.heinen@art.state.ma.us.