Personnel Privacy Statement

This Personnel Privacy Statement (“Statement”) describes how U.S. HealthConnect, Inc. and its subsidiaries and affiliates (collectively, “USHC”) handle the Personal Information (as defined below) of employees, job applicants, contractors, faculty and other staff, the reasons why we collect the information, and how it may be used or disclosed to others.

USHC receives Personal Information from and about you during the course of hiring and employing or engaging you and may continue to receive some Personal Information from you from time to time during the course of your work for USHC. “Personal Information” and similar terms such as “personal data” refer to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

For Employees and Applicants for Full Employment

Categories and Types of Personal Information We May Collect

The information that USHC collects from you will be within one or more of the following categories:

  • Identifiers (A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name and access information, Social Security number, driver’s license number or government-issued identification card number, signature, passport number, or other similar identifiers)
  • Geolocation data (Your device’s IP address for equipment location)
  • Professional or employment-related information (Current or past job history or performance evaluations)
  • Inferences drawn from other personal information (Profile reflecting a person’s preferences and characteristics)

How We Use Your Personal Information

Your Personal Information enables USHC to perform its role as an employer and/or for the purposes of engaging you, including fulfilling its legal obligations under applicable laws and as necessary in connection with USHC’s performance of its contractual and employment obligations to you. Without this information, it would not be possible for USHC to manage its workforce and meet applicable legal obligations. USHC uses certain Personal Information as necessary for its legitimate business interests and purposes, which include, but are not limited to:

What we use your Personal Information for Our reasons for doing so
Employment, including:
  • recruitment and selection;
  • employee on-boarding;
  • payroll administration;
  • pension administration and/or maintenance of 401K/retirement plans;
  • amounts of bonus payments to individuals;
  • health administration/health insurance/benefits;
  • life insurance/benefits;
  • company wellness program;
  • expense reimbursement and management;
  • administration and management of your access to information technology systems;
  • time entry and leave management;
  • promotions;
  • transfers;
  • work-related licenses and credentials;
  • determination of eligibility to work in the United States;
  • training and appraisal, including performance records and disciplinary records;
  • employee and staff surveys;
  • equal opportunities monitoring;
  • administration of separation of employment;handling of employee claims;travel administration;
  • employee appreciation program;
  • any vendor services;
  • and/orany aspect of USHC’s benefit administration including equity-related plans and benefits.

For the performance of our contract with you or to take steps at your request before entering into a contract.

For the purposes of USHC’s legitimate interests in providing employment opportunities, except where such interests are overridden by the interests or fundamental rights of the data subject.

To comply with our legal and regulatory obligations.

Communications, including:

  • contacting others in the event of an emergency;
  • making information available on the intranet and to facilitate communication between and among employees within USHC; and/or
  • for marketing and/or public relations purposes and in connection with the performance of your duties (e.g., USHC may send your contact information to customers and potential customers as part of the marketing and sales process so they can contact you).

For our legitimate interests of providing notifications and other communications within the scope of your employment.

In order to protect the vital interests of the data subject or of another natural person.

Other legal requirements, including:

  • to respond to governmental inquiries or requests from public authorities;
  • to comply with valid legal process or discovery obligations;
  • to protect the rights, privacy, safety or property of USHC, its workers or the public if such a disclosure is proportionate in the individual case;
  • to permit USHC to pursue available remedies or limit the damages that USHC may sustain;
  • to respond to an emergency;
  • to maintain proper business records and other relevant records in respect of our contract, such as records that we have to maintain under relevant accounts or tax laws or records that we have to maintain under other applicable laws or regulations;
  • communicate with you regarding additional uses of your Personal Information beyond the scope of this Statement; and/or
  • to comply with other applicable regulations, policies and procedures.

To comply with our legal and regulatory obligations.

In order to protect the vital interests of the data subject or of another natural person.

Categories of Third Parties With Whom We May Share Your Personal Information

USHC shares certain types of Personal Information with other entities where doing so, among other things: (a) is required by laws or regulations; (b) assists or enables USHC to perform its role as an employer, including the management of its workforce and meeting applicable legal obligations; and/or (c) assists USHC in providing employees with various services and benefits. The categories of third parties with whom USHC may share your Personal Information include:

Payroll Processors
Benefits Administrators
Government Agencies
IT Systems Services and Security Providers
Employee Training Providers
I-9 Verification Vendors
Service Award Vendors
Predictive Analytics Vendors
Background Check Vendors
Financial Institutions
Insurance Carriers
Third Party Credit Check Companies
Prospective Employer
Event Management Vendors
Employee Engagement Survey Companies or Vendors
Project Management System Vendors

For Independent Contractors, Faculty and Applicants for Such Positions

Categories and Types of Personal Information We May Collect

The information that USHC collects from you will be within one or more of the following categories:

  • Identifiers (A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or government-issued identification card number, signature, passport number, or other similar identifiers)
  • Protected classification characteristics under applicable law (Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information))
  • Internet or other similar network activity (If you use USHC devices or other equipment, browsing history, search history, information on your interaction with a website, application, or advertisement)
  • Geolocation data (Any USHC device’s IP address for USHC equipment location)
  • Professional or employment-related information (Current or past job history or performance evaluations)
  • Inferences drawn from other personal information (Profile reflecting a person’s preferences and characteristics)
  • Non-public education information (Depending on the job description, education records directly related to you as maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records)
  • Images/Likeness (Professional image when presenting as a host or guest for educational content on our website or through promotional materials)

How We Use Your Personal Information

Your Personal Information is used by USHC for the purposes of engaging you, including fulfilling its legal obligations under applicable laws and as necessary in connection with USHC’s performance of its contractual obligations to you. Without this information, it would not be possible for USHC to meet applicable legal obligations. USHC uses certain Personal Information as necessary for its legitimate business interests and purposes, which include, but are not limited to:

What we use your Personal Information for Our reasons for doing so

Employment, including:

  • recruitment and selection;
  • contractor/faculty on-boarding;
  • expense reimbursement and management;
  • administration and management of your access to information technology systems;
  • work-related licenses and credentials;
  • determination of eligibility to work in the United States;
  • contractor, faculty and staff surveys;
  • equal opportunities monitoring;
  • travel administration; and/or
  • any vendor services.

For the performance of our contract with you or to take steps at your request before entering into a contract.

For the purposes of USHC’s legitimate interests, except where such interests are overridden by the interests or fundamental rights of the data subject.

To comply with our legal and regulatory obligations.

Communications, including:

  • contacting others in the event of an emergency;
  • making information available on the intranet and to facilitate communication between and among contractors, faculty and other staff within USHC; and/or
  • for marketing and/or public relations purposes and in connection with the performance of your duties (e.g., USHC may send your contact information to customers and potential customers as part of the marketing and sales process so they can contact you).

For our legitimate interests of providing notifications and other communications within the scope of your contracted engagement.

In order to protect the vital interests of the data subject or of another natural person.

Other legal requirements, including:

  • to respond to governmental inquiries or requests from public authorities;
  • to comply with valid legal process or discovery obligations;
  • to protect the rights, privacy, safety or property of USHC, its workers or the public if such a disclosure is proportionate in the individual case;
  • to permit USHC to pursue available remedies or limit the damages that USHC may sustain;
  • to respond to an emergency;
  • to maintain proper business records and other relevant records in respect of our contract, including records that we have to maintain under relevant accounts or tax laws or records that we have to maintain under other applicable laws or regulations;
  • communicate with you regarding additional uses of your Personal Information beyond the scope of this Statement; and/or
  • to comply with other applicable regulations, policies and procedures.

To comply with our legal and regulatory obligations.

In order to protect the vital interests of the data subject or of another natural person.

Categories of Third Parties With Whom We May Share Your Personal Information

USHC shares certain types of Personal Information with other entities where doing so, among other things: (a) is required by laws or regulations; (b) assists or enables USHC to meet applicable legal obligations; and/or (c) assists USHC in providing its contractors and faculty with various services and benefits. The categories of third parties with whom USHC may share your Personal Information include:

Government Agencies
IT Systems Services and Security Providers
Contractor Training Providers
I-9 Verification Vendors
Service Award Vendors
Predictive Analytics Vendors
Background Check Vendors
Financial Institutions
Insurance Carriers
Third Party Credit Check Companies
Prospective Employer
Event Management Vendors
Contractor Engagement Survey Companies or Vendors
Financial Consultants and Auditors
Project Management System Vendors

By providing to USHC the Personal Information and other data referenced above, you agree that USHC may use such Personal Information and other data in accordance with the terms of this Statement.

You also agree and acknowledge that by providing any data to USHC, including Personal Information, that such data will be transferred to, and stored in, the United States. Further, your consent to this Statement followed by your submission of such Personal Information and other data represents your agreement to that transfer.

If you are located in the European Economic Area (the “EEA,” which includes the 27 European Union Member States, Iceland, Lichtenstein and Norway), Switzerland or the United Kingdom (“UK”) (collectively, the “EU”), or if you are in other countries or jurisdictions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information, you consent to any transfer and processing in accordance with this Statement.

USHC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Statement and no transfer of your Personal Information will take place to any organization or country unless there are appropriate controls in place that are consistent with industry standards and applicable laws and regulations, including with respect to the security of your Personal Information and other data.