ExclusionWatch Privacy Notice

Version 1.1
Effective date: September 16, 2025 Last updated: August 5, 2026

ExclusionWatch (“we,” “us,” or “our”) provides the ExclusionWatch service. This Privacy Notice explains how we collect, use, disclose, and retain personal information through the ExclusionWatch website, accounts, applications, communications, and support services.

This Notice does not govern the privacy practices of government publishers, customers, identity providers, payment processors, or other third parties.

1. Our Role

For account administration, security, marketing, billing, and direct communications, ExclusionWatch determines why and how personal information is used.

For roster information submitted by a customer organization, ExclusionWatch generally processes information on that organization’s instructions. The customer determines whose information is submitted, which sources are selected, how candidate matches are reviewed, and what action is taken. Questions from roster subjects should ordinarily be directed first to the organization that submitted the roster information.

2. Information We Collect

Information provided by customers and users

We may collect:

• name, username, work email, organization, title, role, and contact details;
• account invitations, account status, permissions, and organization memberships;
• multifactor-authentication device identifiers and recovery-code records;
• SSO provider, federated subject identifier, email domain, and login status;
• support communications and feedback;
• subscription, plan, tax-exemption, and billing status;
• payment-processor customer and subscription identifiers, but not complete payment-card numbers;
• signup-request information, including organization name, contact name, work email, telephone number, estimated roster size, selected plan, and message;
• source selections, organization settings, and administrative decisions; and
• information entered into review notes, support requests, and other free-text fields.

Workforce and vendor roster information

Depending on the information a customer chooses to provide, roster information may include:

• names, middle names, former names, and aliases;
• dates of birth;
• National Provider Identifiers;
• professional license numbers and states;
• position and employment or contract dates;
• internal or external workforce and vendor identifiers;
• vendor legal names, DBA or former names, vendor type, business address, organization NPI, and the last four digits of a vendor EIN; and
• roster status and duplicate-resolution decisions.

ExclusionWatch does not request Social Security numbers. Customers must not submit Social Security numbers, patient information, clinical information, or Protected Health Information.

Screening, review, and audit information

We may collect or create:

• candidate-match scores and matching reasons;
• potential, under-review, confirmed, and false-positive dispositions;
• reviewer identity, timestamps, notes, and carried-forward decisions;
• exact source snapshots used for a screening run;
• import filenames, file hashes, row counts, validation results, and duplicate decisions;
• compliance reports and exports; and
• audit events recording administrative, roster, screening, review, export, authentication, and security activity.

Public and government-source information

We obtain exclusion, sanction, debarment, provider, licensing, and related records from federal and state government publishers and other official public sources. Those records may contain names, business names, dates of birth, NPI, license information, addresses, action dates, program information, and other publisher-supplied identifiers.

Automatically collected information

When a person uses the Service, we may collect:

• session and CSRF-cookie identifiers;
• login, logout, authentication, security, and rate-limit events;
• device, browser, request, timestamp, and error information needed to operate and secure the Service;
• network address information needed for security, abuse prevention, and troubleshooting; and
• service performance and operational logs.

On the public marketing, supported-sources, free-check, signup, and successful checkout pages, we use Google Analytics and Google Ads measurement to understand how visitors find and use ExclusionWatch and whether an advertising campaign leads to a trial signup. This measurement may collect page URL, referrer, campaign information, browser and device characteristics, approximate location, interaction events, and cookie or similar identifiers. We do not load these measurement tools within authenticated customer dashboards, rosters, screening results, reports, administration, SSO, or multifactor-authentication pages. We do not send roster fields, free-search inputs, names, email addresses, license numbers, NPIs, dates of birth, review notes, or match results to these tools.

Security throttling may use keyed hashes of network addresses or account identifiers rather than storing the original value in the throttle record.

Public single-record searches

The public search accepts only the identifying fields displayed on its form. We use those fields transiently to compare against current source snapshots and return candidate results. The submitted search fields are not added to a customer roster or saved as a compliance screening record. We may retain security and rate-limit information about the request as described above.

3. How We Use Information

We use personal information to:

• provide, operate, secure, and support ExclusionWatch;
• authenticate users, enforce roles, and support SSO and multifactor authentication;
• maintain organization rosters and source selections;
• perform exclusion checks and identify candidate matches;
• enable review, audit history, reporting, and evidence exports;
• detect duplicates, abuse, fraud, and security threats;
• monitor source freshness, load new source snapshots, and send operational alerts;
• administer subscriptions, taxes, sponsored access, and billing;
• respond to signup requests, support requests, and communications;
• improve reliability, usability, source integrations, and matching quality;
• enforce our agreements and protect legal rights; and
• comply with law, legal process, and regulatory obligations.

We do not sell personal information and do not use roster information for targeted advertising.

4. How We Disclose Information

We may disclose information:

• to the customer organization and its Authorized Users according to assigned roles;
• to infrastructure, email, payment, security, and support providers that process information for us under appropriate obligations;
• to a customer-configured identity provider, such as Okta, to complete SSO;
• when directed by the customer;
• to government authorities, courts, or other parties when reasonably necessary to comply with law or protect rights, safety, and security;
• in connection with a merger, reorganization, financing, or transfer of relevant assets, subject to appropriate confidentiality protections; or
• with consent.

Government-source websites are used to retrieve public source data. Customer rosters are not sent to government publishers merely because a source is enabled; matching is performed within the ExclusionWatch environment.

Our current subprocessor information appears in Schedule 3 of the Data Processing Addendum.

5. Cookies

ExclusionWatch uses cookies and similar browser storage that are necessary to:

• maintain authenticated sessions;
• protect forms and requests against cross-site request forgery;
• preserve login and security state; and
• support essential site functionality.

On the limited public pages identified above, Google Analytics and Google Ads measurement may use cookies or similar identifiers to measure visits, site interactions, advertising attribution, and trial conversions. Google explains how it uses information from sites that use its services at Google's business data responsibility page. These tools are not loaded on authenticated application pages.

Third-party checkout or identity-provider pages may use cookies under their own privacy notices.

6. Retention

We retain information for the period reasonably necessary for the purposes described in this Notice, including:

• active roster information for the customer relationship or until Customer deletes it;
• screening runs, dispositions, source evidence, reports, and audit history according to the customer agreement and applicable retention settings;
• account and organization records for the relationship and a reasonable period afterward;
• unsuccessful signup requests for a limited business-development period;
• billing and tax records for legally required accounting periods;
• security records for a period appropriate to investigation and threat prevention; and
• backups until overwritten through the applicable backup cycle.

Our standard operational schedule is seven years for screening evidence and audit history; 24 months for unconverted signup requests; up to 12 months for routine security logs; and 30–35 days for rolling backups.

We may retain information longer when required by law, legal hold, dispute, or enforcement need. Public-source snapshots may be retained to establish the exact evidence used for a historical screening run.

7. Security

We use administrative, technical, and physical safeguards designed to protect the Service and the information it processes. These include role-based access, multifactor authentication, optional organization SSO, transport encryption, network segmentation, restricted secrets, audit logging, security throttling, backups, source-integrity controls, and vulnerability-management practices.

No method of storage or transmission is completely secure. Users should protect authentication devices and downloaded reports and promptly report suspected unauthorized access to contact@exclusionwatch.org.

8. Privacy Choices and Requests

Depending on applicable law and our role, a person may request access, correction, deletion, or information about our handling of personal information.

Roster subjects should contact the customer organization that submitted their information because that organization controls the roster and screening decision. We will assist customers with verified requests as required by our Data Processing Addendum and applicable law.

Requests concerning an ExclusionWatch account, signup request, or direct ExclusionWatch communication may be sent to contact@exclusionwatch.org. We may need to verify the requester’s identity and authority. Authorized agents may be required to provide written authorization.

We will not discriminate against a person for exercising an applicable privacy right.

9. Communications

We send transactional communications such as invitations, verification links, security notices, source alerts, screening alerts, billing notices, and support responses. These messages are necessary to provide or secure the Service.

Marketing communications, if any, will include the choices required by law. Opting out of marketing does not stop transactional service communications.

10. No PHI and Sensitive Information

ExclusionWatch is not a patient-record or clinical system. Customers must comply with the ExclusionWatch No-PHI Policy. Standard ExclusionWatch service is not provided under a Business Associate Agreement.

If prohibited information is submitted, we may isolate or delete it and contact the customer to investigate. Suspected accidental PHI submission should be reported without repeating the sensitive information in email.

11. Children

ExclusionWatch is a business service and is not directed to children under 13. We do not knowingly collect personal information directly from children for their own use of the Service.

12. United States Processing

ExclusionWatch is operated in the United States. Information may be processed in United States locations where ExclusionWatch and its service providers operate.

13. Changes to This Notice

We may update this Notice to reflect changes in the Service, law, or our practices. We will post the revised version with its effective date and provide additional notice when a material change requires it.

14. Contact Us

Privacy questions and requests:

contact@exclusionwatch.org