Privacy Policy
The Towns Foundation Group, Inc: Privacy Policy & Procedures
Policies and Procedures (P&P), it is vital to note that as of October 1, 2025, the Maryland Online Data Privacy Act (MODPA) is in full effect.
This law is particularly strict for health and education-related vendors. It requires "Data Minimization"—meaning you should only collect the data strictly necessary to provide the training.
Here are the remaining two major sections for your P&P manual:
1. Website Privacy & Data Security Policy (MODPA Compliant)
-
Data Collection Limitation: Towns Foundation Group, Inc. only collects personal information (Name, DOB, SSN, Address) that is strictly necessary for Maryland OHCQ certification and regulatory reporting.
-
No Sale of Data: In accordance with MODPA, Towns Foundation Group prohibits the sale of student sensitive data to any third party for any reason.
-
Access Control: Access to student "Consumer Health Data" or personal identifiers is restricted to the Program Director and authorized administrative staff who have signed a Confidentiality Agreement.
-
Data Minimization: We do not track precise geolocation or collect biometric data. All data collected is deleted or de-identified after the 5-year retention period required by COMAR.
2. Classroom Code of Conduct (Student Discipline)
-
Professionalism: Students are expected to behave as "Managers in Training." This includes professional attire, respectful language, and active participation.
-
Technology Use: During instruction, mobile devices must be silenced and put away unless being used for a specific classroom exercise.
-
Academic Integrity: Any form of cheating, plagiarism, or sharing of OHCQ-approved exam questions will result in immediate dismissal from the program without a refund.
-
Non-Discrimination: Towns Foundation Group maintains a zero-tolerance policy for harassment or discrimination based on race, religion, gender, or disability.
-
Confidentiality: Students may share real-world scenarios from their facilities during class. All students agree to keep these discussions confidential to protect resident privacy (HIPAA compliance).
-
Exit Competency Portfolio: To ensure surveyor-readiness, students must demonstrate proficiency by completing the Resident Assessment Tool (RAT), Uniform Disclosure (UD), and Resident Scoring Tool. This portfolio serves as objective evidence of your professional readiness.
-
​