Healthwise Employment Privacy Notice
Ignite Healthwise, LLC (“Healthwise“, “we”, “us” or “our”) respects your privacy and we are committed to protecting the privacy and security of your Personal Data. This Employment Privacy Notice (“Notice”) describes how we process (that is, collect, use, manipulate, store, disclose, share or transfer) Personal Data about you - whether you are working with us as an employee or contractor, or are simply pursuing an employment engagement with us. This Notice also applies during and after your employment engagements, any employment scoping or any employment-seeking interactions with us (your “Covered Relationship”).
It is important that you read and retain this Notice, as well as any other communications, policies, documents, or postings from Healthwise regarding your privacy that we may provide when we are processing your Personal Data.
To make this Notice easier to understand, we have provided a summary to the left-hand side of each section. We also encourage you to contact us (see “How to Contact Us” below) if you have any questions or concerns. If you are working through an agency or contracting service, we encourage you to review that organization’s privacy policies and practices as they may also govern the processing of your Personal Data.
1. SCOPE OF THIS EMPLOYMENT PRIVACY NOTICE
This Notice applies to Employees and Applicants, anywhere in the world, who have a Covered Relationship with Healthwise.
This Notice applies globally to all current and former employees and contractors, whether employed directly with Healthwise or working as an independent contractor or as a contract worker through an agency or contracting service, (collectively “Employees”). Furthermore, this Notice applies to current and former job seekers and/or applicants and those individuals whose Personal Data we may process regarding potential interest in employment with Healthwise (collectively “Applicants”).
This Notice applies both to Personal Data processing activities that we conduct directly as well as processing activities that we may direct our agents or contracting services, or other authorized third parties, to conduct during your Covered Relationship with Healthwise.
This Notice does not create or form part of any contract for employment, whether permanent or temporary, or any other contract to provide services to or receive services from Healthwise. When we use the terms ‘employment’ or ‘employee’ throughout this Notice, we do so for simplicity and in no way is such use intended to imply the existence, where there is none, of an employment relationship between you and Healthwise.
Please remember that our
Terms and Conditions of Use,
Terms of Use of Healthwise Products, our
Healthwise Global Privacy Notice and other policies and procedures, as applicable, also govern your Covered Relationship with us and any use of our products, networks, systems, application, assets, services or websites.
2. YOUR RIGHTS AND PREFERENCES
Healthwise allows you to exercise your privacy rights and manage how we use your information.
Privacy and data laws in different countries and regions around the world give individuals certain rights in relation to their Personal Data. We conduct our global employment privacy practices according to this Notice, our
Healthwise Global Privacy Notice and the relevant laws of the countries or regions in which we interact with you.
3. INFORMATION WE COLLECT ABOUT YOU
Healthwise collects your Personal Data for specified purposes related to the Covered Relationship.
When used in this Notice, “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual, and includes ‘personal data’ or “personal information” as used in various applicable data protection laws. Personal Data does not include data that cannot be associated with you, such as aggregated, de-identified or anonymized information (“Anonymous Information”).
We may process the following categories of Personal Data about you during and after your Covered Relationship with Healthwise:
- Personal Identifiers:
- Personal contact details such as name, title, addresses, telephone numbers and email addresses.
- Bank account details, payroll records, and tax status information.
- Driver’s license number, passport number, nationality/visa status, or related information.
- Social Security number, national identification number, or other government-issued numbers.
- Protected Classifications and Sensitive Personal Data:
- Your date of birth, sex and likeness information related to your identity.
- Your marital status and dependents related to your tax and benefits administration.
- Information about your race, ethnicity, religion, disability, veteran’s status, or sexual orientation if you choose to provide it during the application or onboarding processes, or to the extent that it is used to provide work accommodations to you. We use this information to support our efforts to attract and maintain a diverse workforce, including for reporting required by law.
- Information about your health, such as medical conditions and health and sickness records, when you provide this information to us or authorize its disclosure to us in administering and maintaining your healthcare and other benefits, and when you provide this information to us in connection with efforts to address site security and health and safety concerns. This includes details of any absences (other than holidays) from work, including family leave and sick leave; information related to biological screenings or testing for controlled substances; information provided through health surveys and questionnaires, records related to administering and maintaining your healthcare and other benefits; and information about a condition needed for processing benefits when you leave a Covered Relationship and the reason is related to your health. To understand how protected health information is processed by your employee benefit plan, please see the Notice of Privacy Practices for the Healthwise Employee Benefit Plans. Processing by your employee benefit plan is not covered in this Notice.
- Background checks (for select Employees and Applicants in certain countries).
- Internet or Other Electronic Network Activity Information:
- We collect information about your use of Healthwise computers and networks, including your use of the internet and your email or other electronic communications when you are using company websites or systems, or company computers or other company-provided devices such as mobile phones or tablets.
- The level of monitoring of your use of company equipment and systems may vary depending on your location, applicable law, the type of relationship you have with us, and the type of work that you perform for Healthwise. We monitor and may restrict access to our systems, even when using personal devices (e.g., we monitor and may restrict access to certain websites when you access our guest WIFI/network or systems).
- For our Employees, more information about how Healthwise protects its digital intellectual property, trade secrets, and our systems and equipment monitoring policies and procedures, is available at https://policy.healthwise.org.
- Location Data:
- We may collect geolocation data about you where it is relevant to the fulfillment of your employment duties at Healthwise.
- We collect information regarding your access to and use of our facilities and systems (e.g., badges, login data, recordings, security devices).
- We may collect data regarding your operation of company owned, issued or compensated devices (e.g., computers, mobile phones).
- Audio, electronic, visual, thermal, or similar information:
- We may collect photographs of you for identity verification. Your image may be recorded on building security cameras or through video conferencing if you come to one of our locations or engage in video conferencing with us.
- Your telephone calls, online meetings or other communications over electronic channels and applications may be monitored or recorded when accessing company resources (e.g., IT services), or interacting with customers or members of the public.
- We do not routinely collect any of your thermal, olfactory or similar biometric information, but reserve the right to do so for site security or if health and safety concerns require us to do so.
- Professional or employment-related information:
- We collect information about your professional and employment-related background as part of the recruitment process (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of your application to work at Healthwise, and information from publicly-available social media or networking sites).
- During the Covered Relationship, we collect information regarding your wages, salary, compensation, annual leave, retirement, work performance, disciplinary actions, grievances, and/or internal investigations.
- We may also collect information regarding job titles, salary history, work history, working hours, holidays, absences, training records, professional memberships, board memberships, and other professional activities or roles.
- During the Covered Relationship, we may collect information from publicly available social media or networking sites or applications, and from other electronic search services.
- Your employment records include information you provided during the application process about the educational institutions you have attended or your level of education, including educational records. We also collect and maintain information about any professional licenses you hold, certifications you receive, or additional education or training you undertake during your Covered Relationship.
4. HOW WE COLLECT YOUR PERSONAL INFORMATION
Personal Data is collected during Covered Relationship activities performed by us, you, or our authorized third parties.
We may collect Personal Data about Employees and Applicants through the application and recruitment process, directly from candidates, from employment agencies, from employers of contractors, through screening services, and/or background-check providers. We may collect additional information from third parties including former employers, credit reference agencies, publicly available websites such as LinkedIn, or other sources that supply employment or identity verification services.
We may collect additional Personal Data in the course of job-related activities throughout the time period that you work with us or receive benefits from us. Such collection may occur by you directly providing us with your information or we may automatically collect information about you, such as through monitoring Healthwise computer and systems access and usage.
Healthwise Covered Relationship activities are intended for and directed to adults, not children. Applicants who are under the applicable legal age of employment in their geography should not supply any Personal Data to any Healthwise or affiliate website for the purposes of applying for, obtaining or maintaining a Covered Relationship with Healthwise.
5. HOW WE USE YOUR PERSONAL INFORMATION
Healthwise uses your Personal Data to support activities related to your Covered Relationship.
Unless we specifically disclose otherwise, you understand that we may use any of your collected Personal Data for any of the purposes described in this Notice (as permitted by applicable law), including:
- Decisions related to employment:
- making decisions about your recruitment; determining whether to offer you a position and on what terms;
- ‘Professional or employment-related information’ may be used for reviewing your performance; evaluating your development as an Employee; setting your job duties and assessing our staffing needs; assessing your qualifications for other roles within the company or promotion; determining salary and compensation; preparing for grievance or other disciplinary procedures, including termination;
- dealing with legal disputes involving you or other Employees, including accidents at work; or
- ascertaining your fitness for work.
- Business Purposes:
- conducting data analytics studies to review and better understand employee demographics, performance, retention, and attrition rates;
- ascertaining and fulfilling education, training, and development requirements and opportunities; or
- ensuring the effective operation of our facilities, resources and systems, and enabling authorized access to these facilities, resources and systems by Employees and Applicants.
- Administering payments and benefits:
- making tax and other required deductions;
- provisioning benefits;
- making decisions about salary and compensation.
- Security measures and complying with health and safety obligations:
- ensuring the physical safety of, and lack of threats to, our facilities, resources, Employees, Applicants and other people interacting with Healthwise;
- preventing fraud and securing our systems, data, resources, and facilities from unauthorized access or exploitation;
- monitoring compliance with our IT policies;
- ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems, and preventing malicious software distribution; or
- investigating theft and other illegal activities.
- Compliance:
- verifying your identity;
- ensuring that you are legally permitted to work in your geography of hire;
- conducting internal investigations; or
- monitoring diversity in accordance with the applicable law.
- We may also process your Personal Data for other purposes with your consent or at your direction, which consent you may withdraw or modify at any time by contacting us. Such purposes shall be specified from time to time to you.
6. DISCLOSURE OF YOUR PERSONAL
We disclose your Personal Data to support your Covered Relationship activities with us.
Healthwise does not sell or share your Personal Data with third parties for their commercial use without your consent.
We do not sell your Personal Data to any third parties.
We may disclose any Personal Data as described in this Notice to third party service providers we use to support our business.
Through our contracts with our service providers, we strive to require that they only use Personal Data we share with them for the purposes for which we disclose it to them. The categories of service providers that we share information with and the services they provide are:
- Payroll services providers that assist us in calculating, handling, and disbursing your salary, benefits, and other compensation.
- Auditing and accounting firms that assist us with the creation, maintenance and auditing of our financial and business records.
- Professional services consultants that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
- Vendors that assist with application and employment processes, including assessing candidate qualifications, providing the platform through which candidates submit their candidacy, conducting background checks, and verifying compliance with Healthwise policies and applicable laws relating to employment.
- Data analytics services that analyze data from internal and external sources and assist with various data trends to improve our employee and customer relationships and experiences.
- Security vendors that assist with security incident verification and response, service notifications, and fraud prevention.
- IT vendors that assist with system design, architecture and implementation, hosting and maintenance, data and software storage, and network operations.
We may also disclose Personal Data to other external parties when required by law or to protect Healthwise or other persons, as described in this Notice.
We may disclose Personal Data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale or other transfer of some or all of Healthwise’s assets, in which Personal Data held by Healthwise about our Employees and Applicants is among the assets transferred.
We may disclose Anonymous Information without restriction.
7. DATA SECURITY
We provide security measures for your Personal Data processed during Covered Relationship activities.
We strive to implement measures to help safeguard your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use physical, administrative, and technical safeguards for these purposes. Depending on the data and system, these may include data minimization, aggregation, anonymization, cyber and logistics security, encryption, physical security, business continuity and disaster recovery, and risk management systems and processes.
8. DATA COLLECTION, DATA RETENTION AND MANAGING YOUR DATA
You may have the right to exercise certain data protection rights, including the right to request the deletion of, amendment of or access to your Personal Data.
Healthwise will not discriminate against you if you choose to exercise your privacy rights.
Healthwise has adopted a global view on privacy with the intent of providing our employees with strong privacy rights regardless of where they reside. We have attempted to recognize and implement high standards for privacy rights compliance by recognizing the tenets of the California Consumer Privacy Act of 2018 (“CCPA”) as our standard for providing privacy protections to our employees.
Extending the privacy rights offered under the CCPA, our U.S. employees have certain privacy rights including:
- The right to know, at or before the point of collection, the categories of Personal Data to be collected and the purposes for which the categories of personal information will be used. We have detailed these categories and purposes in this Notice.
- The right of private action in the event of a negligent data breach.
Notwithstanding the foregoing, as we have employees working with us from many different states in the U.S., we seek to comply with state privacy laws that apply where our employees reside.
Your Personal Data is retained for the duration of your Covered Relationship with Healthwise, plus a reasonable time period thereafter, and as necessary to fulfil our business purposes disclosed in this Notice. The specific duration of retention depends on many factors, including the record type, your relationship with Healthwise, and your employment location. Our
Healthwise Global Privacy Notice provides additional information on how we will respond to you if you exercise your data protection rights in accordance with applicable data protection laws.
With respect to Covered Relationship activities with Healthwise, Healthwise is considered to be the “controller” of your Personal Data under applicable data privacy regulations. Other entities that we work with during Covered Relationship activities may also act as controllers of your Personal Data and you should contact them if you have any questions about how they use your Personal Data.
9. CHANGES TO OUR NOTICE.
We may make changes to our Notice or our supporting privacy procedures at any time.
From time to time we may change this Notice, our
Healthwise Global Privacy Notice, or any of our supporting privacy procedures. We reserve the right to make such changes at any time and without prior notice to you. If we make material changes to the way we process your Personal Data under the Covered Relationship, we will provide you notice by making the most current version of this Notice, our Global Privacy Notice, and/or any supporting privacy procedures (to the extent that such procedures are normally made publicly available by Healthwise) available to you, such as by posting on our website, sending it via email or other company communication channels, or by publishing it in our Employee Handbook. Please review any changes we provide carefully.
All changes to this Notice are effective immediately upon publication and your continued Covered Relationship activities with us shall constitute your consent to all changes.
10. HOW TO CONTACT US
If you have questions or comments about this Privacy Notice, you may contact us by email, telephone or direct mail.
- Via Email: privacy@healthwise.org
- Via Telephone: 1-800-706-9646
- Via Direct Mail:
Attn: Legal, Ignite Healthwise, LLC
283-299 Market Street
Gateway Center 2, 4th Floor
Newark NJ 07102
Last Modified: April 30, 2024