Thank you for visiting the Web site of the State Ethics Commission (Commission).  Your privacy is one of our top priorities.  The following policy applies only to the use of the Commission's Website.  Other Websites operated by other state agencies have different policies.  We strongly suggest that you read the privacy policies for each Commonwealth Website that you visit, and any external site that you visit through a link appearing at this site.  The Commission’s Website permits the use of certain Google tools.  Google collects information about persons who use its tools, as described further below, and we strongly suggest that anyone using Google tools on this Website read Google’s privacy policy, a link to which is provided below.

A Privacy Partnership.  Your privacy with respect to the use of this Web site results from a partnership between the Commonwealth and you, the user.  At this Web site, we attempt to protect your privacy to the maximum extent possible. Information that we receive in the context of a request for advice or an investigation is confidential by law, Massachusetts General Laws Chapter 268B, Sections 3(g) and 4(a) and (b), and 930 Code of Massachusetts Regulations Section 3.00, and is so maintained by us.  However, because some of the information that we receive through this Web site is subject to the Public Records Law, Massachusetts General Laws Chapter 66, Section 10, we cannot ensure absolute privacy other than as required by the statutes and regulations referenced above.  Information that you provide to us through this site that is not required by law to be maintained confidential may be made available to members of the public under the Public Records Law.  This policy informs you of the information that we collect from you at this site, what we do with it, to whom it may be disseminated, and how you can access it.  Based on this information, you can make an informed choice about your use of this site.  You can maximize the benefits of your privacy partnership with the Commonwealth by making informed choices about whether to share personally identifiable information with us through this site.

Personally Identifiable Information. We use the term "personally identifiable information" to mean any information that could reasonably be used to identify you, including your name, address, e-mail address, or any combination of information that could be used to identify you.

Information Voluntarily Provided by You. This site collects voluntary information from you through any e-mail messages you choose to send to us, such as your e-mail address and any other information you choose to give us to help us answer your inquiry.

Information Automatically Collected and Stored by this Site. This Website does not use permanent "cookies" (the term “cookies” is defined below).  However, the site uses temporary "session cookies" to allow visitors to interact with the Mass.gov Portal and to use online applications.  "Session cookies" do not allow us to personally identify a visitor. These cookies are stored only in memory and are deleted when the user's browser is shut down.

This site does collect and store indefinitely your Internet Protocol ("IP") address, (which does not identify you as an individual), as well as information about the date and time of your visit, whether a file you have requested exists, and how many "bytes" of information were transmitted to you over the Web from this site.  We use your IP address to assess the frequency of visits to this site and the popularity of its various pages and functions.  We will not attempt to match any personally identifiable information that you provide to us through your IP address.  If we receive a request for your IP address from a criminal justice agency and we determine that there are reasonable grounds to believe that providing your IP address would provide information that is relevant and material to a criminal investigation, then we may comply with that request.

Google Tools and Collection of Information by Google.   The Commission’s Website uses and permits the use of several Google tools:  Google Analytics, Google Docs, and Google Sheets.  We use Google Analytics to collect information about the use of the Website so that we can make improvements to it.  We use Google Docs and Google Sheets to collect certain public information from municipalities about the classification of municipal positions.  Google collects information from persons who use its tools, including the following types of information:  device-specific information (hardware model, operating system version, unique device identifiers, and mobile network information including phone number); server log information (search queries, phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information, types of calls, IP address, device event information, and cookies that uniquely identify your browser or Google account); location information; unique application numbers; and local storage.  Google may use cookies and similar technologies to collect and store information from users of its tools.  We suggest that you review Google’s privacy policy, https://www.google.com/intl/en/policies/privacy/, before using any Google tool.  Google’s privacy policy describes steps that you can take to limit Google’s collection of information about you.

Dissemination of Your Personally Identifiable Information.  We do not sell any personally identifiable information collected through this Web site.  However, once you voluntarily submit personally identifiable information to us through an e-mail, its dissemination is governed by the Public Records Law, the Fair Information Practices Act (Massachusetts General Laws Chapter 66A), Executive Order 412, and other applicable laws and regulations.  Requests for advice under the conflict of interest law, and complaints about alleged violations of the conflict of interest law, are confidential pursuant to Massachusetts General Laws Chapter 268B, sections 3 and 4.  For this reason, part or all of the information you send us may be provided to a member of the public in response to a public records request, but only if it is not a confidential request for advice or complaint.  Information that you voluntarily submit will be disclosed only to Commission employees with a "need to know" for purposes of fulfilling their job responsibilities, who will only use that information to answer your questions, respond to any requests for assistance, and fulfill applicable legal obligations.  Where appropriate, we may provide the information submitted by you to the person or company that is the subject of your inquiry, or to a government agency responsible for the matters in your communication.

Your Access and Opportunity to Correct.  The Public Records Law and the Fair Information Practices Act provide you certain rights to get information about you that is in our records.  To learn more about the circumstances under which you can get and correct this information, please click on the above references to these laws.

Security. Because this site does not encrypt incoming e-mail, you should not send information that you consider highly sensitive through this Web site.  We use standard security measures applicable to Commonwealth agencies to ensure that personally identifiable information is not lost, misused, altered, or unintentionally destroyed.  We also use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.  Except for authorized law enforcement investigations, no attempts are made to identify individual users or their usage habits.

Special Protections Against Misuse Of Personally Identifiable Information Within Commonwealth Offices.  In 1999, then-Acting Governor Swift issued Executive Order 412, which enhanced the privacy protection given to any information about you as a named individual held by the Executive Department of state government.  Executive Order 412 limits the collection and dissemination of personally identifiable information within the Executive Department.  This site complies with Executive Order 412, so all of the personally identifiable information that you submit to this site is given the privacy protections set forth in Executive Order 412.

Policy changes.  We will post changes to this policy at least 30 days before they take effect.  Any information we collect under the current privacy policy will remain subject to the terms of this policy.  After any changes take effect, all new information we collect, if any, will be subject to the new policy.

Contact Information.  For questions about your privacy while using this Web site, please contact David Giannotti at David.Giannotti@state.ma.us.

DEFINITIONS:

Cookies are files that a Web site can place on your computer.  A cookie file contains unique information that a Web site can use to track such things as your password, lists of Web pages you have visited, and the date when you last looked at a specific Web page, or to identify your session at a particular Web site.  A file allows the Web site to recognize you as you click through pages on the site and when you later revisit the site.  A Web site can use cookies to "remember" your preferences, and to record your browsing behavior on the Web.  Although you can prevent Web sites from placing cookies on your computer by using your browser's preference menu, disabling cookies may affect your ability to view or interact with some Web sites.

An " Internet Protocol Address" or "IP Address" is a series of numbers that identifies each computer and machine connected to the Internet.  An IP address enables a server on a computer network to send you the file that you have requested on the Internet.  The IP address disclosed to us may identify the computer from which you are accessing the Internet, or a server owned by your Internet Service Provider.  Because it is machine-specific, rather than person-specific, an IP address is not, in and of itself, personally identifiable information.

Approved:  May 2009
Revised:  December 2015