County of Santa Clara Website Privacy Policy

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1. Introduction

Key Points: The County of Santa Clara (“County”) takes your privacy seriously, including when you visit County websites.

Thank you for visiting County websites and reading this Privacy Policy (“Policy”). For purposes of this Policy, “County websites” means all of the following:

webpages on the SantaClaraCounty.gov domain (i.e., [DepartmentName].SantaClaraCounty.gov);
webpages on the sccgov.org domain (i.e., [DepartmentName].sccgov.org);
webpages on the scvh.org domain (i.e., [DepartmentName].scvh.org); and
webpages on the valleyhealthplan.org domain.

This Policy includes explanations of:

What information we collect
What information you agree to voluntarily share with us
Why we collect this information
How we share and disclose your information

2. Information We Collect and You Share

2.1 Information We Collect

Key Points: We collect several categories of information, including IP address, date and time of visit, and which webpages you visit on County websites.

Website analytics companies may use this information as well, typically in aggregate, to determine, for example, which webpages get the most or least traffic.

When you access County websites, we collect several categories of information, including the following:

Your Internet Protocol (IP) address (a unique set of numbers and/or letters that generally identifies the network from which devices access the internet)
The referring address, if any (this would tell us the address of the website you used to get to the County websites)
The size and resolution of your monitor and the size of the browser window
The type of browser (e.g., Firefox, Edge, Chrome) used to access County websites
The operating system (e.g., Windows, Mac OS, Unix) used to access County websites
The city in which your IP address originates
The date and time of your visit, and the total time you spend on County websites
The time you spend on each webpage and in what order those webpages were visited
The internal links you click

We provide this information to website analytics companies. These companies typically aggregate the information and present it in a format that allows us to quickly determine how many people are visiting County websites, which webpages are most popular, and other similar information. For County of Santa Clara Health System HIPAA Covered Entity departments (i.e., Santa Clara Valley Medical Center Hospital and Clinics, O’Connor Hospital, St. Louise Regional Hospital, the Behavioral Health Services Department, Custody Health Services, Valley Health Plan, and parts of the Public Health Department), IP address information is anonymized before it is shared with analytics companies, and this sharing is covered by a business associate agreement.

2.1.1 Information Collection Methods

Key Points: We use certain technologies to collect information relating to visits to County websites. Other third-party services may do so as well.

We obtain some of the information described in Section 2.1 by using technologies such as cookies and tags. These technologies allow us to provide website functionality and to understand how you interact with County websites.

For County websites other than those of County of Santa Clara Health System Covered Entity departments, as described in Section 2.1, we also embed some content on County websites using third-party web widgets and services, such as YouTube. These third parties may set their own cookies and similar technologies for functional and information collection purposes. They may have their own privacy, security, terms of service, and accessibility policies applicable to the features they provide. For more information about third-party services and their policies, please visit their websites.

2.1.2 Why We Collect This Information

Key Points: We typically use this information to help understand how users interact with County websites, maintain the websites’ functionality, and improve the user experience.

We collect the information described in Section 2.1 to understand how users interact with County websites and to promote website functionality. For example, cookies and similar technologies can tell us the number of visitors the website receives, whether and how often individuals return, and what they look for when they arrive. This helps us understand what people are looking for, which webpages are most useful, and other similar information that we can use to improve the experience of visiting County websites.

2.2 Information You Agree to Voluntarily Share

Key Points: You can choose to share other kinds of information, such as by filling out forms or paying for County services.

By accessing County websites, you agree to voluntarily share certain information with us. For example, you may provide credit card or bank information when you pay your property taxes; or your name and contact information when you book a campsite; or your name, email, and address to receive a newsletter or other correspondence and interactions.

2.2.1 Categories of Information

Key Points: This information includes email addresses and payment details, among other categories.

Depending on the transaction or service requested, the categories of information that you might voluntarily agree to share may include, but are not limited to:

Your email address and contents of the email
Financial information, such as credit card or bank account numbers (e.g., to process payments for County services)
Social services details, such as seeking information on becoming a foster parent
Public safety information, such as paying a parking ticket
Other information that may be collected through an online form

2.2.2 Why We Ask You to Share This Information

Key Points: This information from you allows us to complete your online requests and transactions more efficiently.

This information from you is used to fulfill the purpose for which you are providing the information, such as to complete your transaction or route requests to the appropriate department.

3. What We Do with Information You Agree to Voluntarily Share

3.1 General Principle

Key Points: As a general principle, your information will not leave the County unless it's necessary and authorized by law.

We will not share, sell, or otherwise disclose information you agree to voluntarily share while accessing County websites to third parties, except as necessary and authorized by law, or where you provide consent to complete a transaction you authorize, or to provide services you request. For example, we may share information among County departments and other government agencies as necessary to provide services to you and when authorized by law.

3.2 Service Providers

Key Points: We may share your information with our authorized service providers as necessary to improve County websites and to provide services to you.

We engage authorized service providers to improve County websites and to provide services to you, including for website analytics (as described above in Section 2.1) and credit card payment processing. In order for these service providers to appropriately deliver services, we may share information with them relating to your visit to the County website.

3.3. Public Records Law

Key Points: Information collected and shared through the County website may be subject to a public records request under the California Public Records Act.

The California Public Records Act (Government Code Section 7920.000 et seq.) exists to ensure that government is open and that the public has a right to have access to records and information possessed by the government, unless an exemption or exception exists in federal or state law. Information collected and shared through the County website may be subject to public access unless an exemption or exception applies. Some of these exemptions and exceptions help maintain the privacy of individuals. In the event of a conflict between this Privacy Policy and the California Public Records Act or other law governing the disclosure or protection of information and records, the applicable law will control.

3.4 Information Security

Key Points: We protect your information using NIST-based cybersecurity standards.

We apply security controls and protections developed by the National Institute of Standards and Technology (NIST) to ensure the confidentiality, availability, and integrity of systems and data is maintained at all times. These controls and protections are in addition to any that the County Information Security Office would apply to a County department on the basis of existing legal requirements (such as requirements related to protected health information) or policies.

4. This Policy Does Not Apply to Non-County Websites

Key Points: If you go to a non-County website from the County websites, the destination website’s privacy policy will apply.

The County websites contain links to non-County websites. These non-County websites are not within our control and may not follow or be similar to the County’s privacy, security, or accessibility polices. Once you link to a non-County website, you are subject to the policies of that destination website, and you should contact the owner/operator of that destination website if you have any questions or concerns. For more information, please see the County’s Links Policy.

5. Changes to This Policy

Key Points: This Policy may be revised from time to time. A brief summary of previous changes can be found below.

We may revise this Policy from time to time. In the event of major substantive changes, we will provide a brief summary of those changes in the below table so that you can keep track of the differences between the latest version and the prior version.

Version	Content	Status/Comments
V1.0	Prior version of Santa Clara County Website Information Privacy Policy	Last updated June 2016.
V2.0	Revised and updated	Finalized November 2019 (Revisions focused on clarifying data collection practices and improving readability).
V3.0	Revised and updated	Finalized December 2021 (Updated to include new sub-domain naming conventions, clarified language on information collection technologies, and other general revisions).
V4.0	Updated	Updated May 2023 (Updated the California Public Records Act citation).
V5.0	Revised and updated	Finalized July 2023 (Updated to further explain sub-domain naming conventions, and to clarify the scope and applicability of data collection and use across County websites for different departments).
V6.0	Revised and updated	Finalized February 2024 (Updated to further clarify the scope and applicability of data collection and use across County websites for different departments)

6. Contact Us

Key Points: We welcome your questions and feedback.

We welcome any questions or feedback you may have about this Policy. Please feel free to contact our Privacy Office at: [email protected].