Zelis Applicant & Associate Privacy Notice
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1. Introduction
Zelis respects your privacy and is committed to maintaining the confidentiality and security of your Personal Information. During the course of your employment by Zelis, we collect Personal Information responsibly and in accordance with applicable data privacy laws, including but not limited to, California Consumer Privacy Act (CCPA).
For purposes of this Applicant & Associate Privacy Notice (“Notice”), Personal Information is defined as: any information or set of information relating to you, including (a) all information that identifies you or could reasonably be used to identify you, and (b) all information that any Applicable Law treats as Personal Information.
Sensitive Personal Information is a subset of Personal Information consisting of the specific categories of information listed below. Importantly, privacy laws such as the CCPA only treat this information as Sensitive Personal Information when we collect or use it to infer characteristics about an Associate.
Personal Information and Sensitive Personal Information do not include: (1) publicly available information, including from government records, from widely distributed media, or that the employee made publicly available without restricting it to a specific audience, (2) lawfully obtained, truthful information that is a matter of public concern, (3) deidentified or aggregated Associate information, and/or protected health information (PHI) collected and used in connection with your Zelis health plan benefits, which collection and use is addressed in a separate policy.
The purpose of this Notice is to provide notification to potential, former, and current full-time and part-time Associates, volunteers, contractors, and interns (collectively referred to throughout this Notice as “you”, “your”, “their”, or “Associates”) as to how Zelis uses and discloses your Personal Information. For clarity and the purposes of this Notice, “Associates” also refers to applicants, non-Associates, consultants and contractors engaged by Zelis, even though they are not Associates of Zelis.
It is important that you read and understand this Privacy Notice. If you have questions or do not understand it fully, please seek additional information by contacting the Privacy Office at privacyoffice@zelis.com or by contacting your P&C partner.
This Privacy Notice is not a contract and does not create any contract of employment or other rights or obligations. Employment with the Company is “at will,” and either the Associate or the Company may terminate employment at any time, with or without cause, reason, or notice. This Privacy Notice does not apply to our collection and use of Personal Information in a consumer or business-to-business capacity.
2. Scope
When we mention “Zelis”, the “Company”, “we”, “us” or “our” in this Notice, we are referring to Zelis Healthcare, LLC, which is ultimately responsible for processing your Personal Information as your employer. This Notice applies to how Zelis collects and uses your Personal Information as part of your employment relationship with Zelis.
3. Categories of Personal Information and Sensitive Personal Information We Collect
We may collect the following categories of Personal Information and Sensitive Personal Information about you:
4. Sources of Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources which includes, but is not limited to, the following:
As an employer, Zelis collects, uses, and discloses your Personal Information in connection with your working relationship with us and in order to comply with Zelis’ legal obligations in accordance with applicable law and contractual obligations. We use, and may disclose to third parties who assist us with these functions, Personal Information for the following purposes:
We may use or disclose Sensitive Personal Information for the following statutorily approved reasons:
We may disclose the Personal Information we collect, including Sensitive Personal Information, to others for the business purposes described in Section 5, such as to engage service providers to help us administer our P&C functions, benefits, or plans, etc. For example, we may disclose information from the Zelis’ equipment or your use of our network, systems, or equipment to a service provider that provides us with data and cybersecurity services.
7. Sales and Sharing of Your Personal Information
We do not sell your Personal Information to third parties. We also do not share your Personal Information with third parties for cross-context behavioral advertising purposes. To the extent you opt into text notifications from Zelis, Zelis will not disclose your opt-ins and consents to any third party unless required by legal and contractual agreements
8. Your Rights Regarding Your Personal Information
You have the following rights regarding your Personal Information maintained by Zelis:
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information, including the specific pieces of Personal Information we have collected about you. Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make two (2) right to know and data portability requests in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you the categories of:
Right to Delete
You have the right to request Zelis to delete Personal Information collected from and about you, subject to certain exceptions and in accordance with applicable law and contractual obligations. Zelis will need to assess federal, state, and local retention requirements when responding to your deletion request. There are instances in which Zelis cannot agree to your request to delete Personal Information in accordance with applicable law and contractual obligations.
Instructions for submitting a verifiable request are provided below.
Right to Correct Inaccurate Personal Information
You have the right to request that Zelis corrects Personal Information that is inaccurate.
Instructions for submitting a verifiable request are provided below.
Right to Limit Use and Disclosure of Sensitive Personal Information to Permitted Purposes
You have the right to request that Zelis limits use and disclosure your of Sensitive Personal Information, defined above. However, this right only applies to use of Sensitive Personal Information other than what would be “reasonably expected by an average” consumer/employee, so there are some exceptions.
Right to Non-Discrimination
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under certain applicable law, including the CCPA and in accordance with applicable Zelis policies and law.
Instructions for submitting a verifiable request are provided below.
9. How to Exercise Your Rights
To submit a request to exercise any of your rights, please email privacyoffice@zelis.com.
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know or for data portability twice within a 12-month period.
Verification Process and Authorized Agents
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your Personal Information. To designate an authorized agent, please speak to your P&C partner and put in a ticket with P&C Connect. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your Personal Information.
We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the Personal Information relating to you.
Responding to Your Requests to Know, Delete, or Correct
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please email the Privacy Office at privacyoffice@zelis.com.
We strive to respond to a verifiable request within 45 days of you sending it to us. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will email you with our response, which will specify whether we can meet your request. If we cannot meet your request, either in whole or in part, we will explain the reason, subject to any legal or regulatory limitations. Some laws may permit or require us to deny access to some of the Personal Information we have about you, or we may have destroyed, deleted, or anonymized your Personal Information in accordance with our records retention policies and obligations.
For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another.
10. Retention of Personal Information
We retain your Personal Information during the course of your employment by or providing services to Zelis in accordance with applicable law and contractual obligations. We keep this information throughout your employment or application process with Zelis and for a specific time afterward in accordance with our Records Retention Policy and applicable law. This period is determined by our legal responsibilities, such as financial and equal opportunity reporting, as well as the statutory periods needed to resolve disputes, handle legal claims, perform audits, and enforce agreements.
11. Security
We have implemented reasonable measures designed to secure your Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. We also limit access to Personal Information to those Associates, agents, service providers, and contractors that have a legitimate business need for such access.
12. Contact Us
If you have any questions about our collection or use of your Personal Information, please contact the Privacy Office at privacyoffice@zelis.com or contact P&C via P&C Connect.
13. Changes to this Privacy Notice
We may periodically modify this Privacy Notice and will provide such updates to you via email, posting it on ZHUB, or by otherwise distributing this to you as part of updates to our policies and procedures.
Zelis respects your privacy and is committed to maintaining the confidentiality and security of your Personal Information. During the course of your employment by Zelis, we collect Personal Information responsibly and in accordance with applicable data privacy laws, including but not limited to, California Consumer Privacy Act (CCPA).
For purposes of this Applicant & Associate Privacy Notice (“Notice”), Personal Information is defined as: any information or set of information relating to you, including (a) all information that identifies you or could reasonably be used to identify you, and (b) all information that any Applicable Law treats as Personal Information.
Sensitive Personal Information is a subset of Personal Information consisting of the specific categories of information listed below. Importantly, privacy laws such as the CCPA only treat this information as Sensitive Personal Information when we collect or use it to infer characteristics about an Associate.
Personal Information and Sensitive Personal Information do not include: (1) publicly available information, including from government records, from widely distributed media, or that the employee made publicly available without restricting it to a specific audience, (2) lawfully obtained, truthful information that is a matter of public concern, (3) deidentified or aggregated Associate information, and/or protected health information (PHI) collected and used in connection with your Zelis health plan benefits, which collection and use is addressed in a separate policy.
The purpose of this Notice is to provide notification to potential, former, and current full-time and part-time Associates, volunteers, contractors, and interns (collectively referred to throughout this Notice as “you”, “your”, “their”, or “Associates”) as to how Zelis uses and discloses your Personal Information. For clarity and the purposes of this Notice, “Associates” also refers to applicants, non-Associates, consultants and contractors engaged by Zelis, even though they are not Associates of Zelis.
It is important that you read and understand this Privacy Notice. If you have questions or do not understand it fully, please seek additional information by contacting the Privacy Office at privacyoffice@zelis.com or by contacting your P&C partner.
This Privacy Notice is not a contract and does not create any contract of employment or other rights or obligations. Employment with the Company is “at will,” and either the Associate or the Company may terminate employment at any time, with or without cause, reason, or notice. This Privacy Notice does not apply to our collection and use of Personal Information in a consumer or business-to-business capacity.
2. Scope
When we mention “Zelis”, the “Company”, “we”, “us” or “our” in this Notice, we are referring to Zelis Healthcare, LLC, which is ultimately responsible for processing your Personal Information as your employer. This Notice applies to how Zelis collects and uses your Personal Information as part of your employment relationship with Zelis.
3. Categories of Personal Information and Sensitive Personal Information We Collect
We may collect the following categories of Personal Information and Sensitive Personal Information about you:
| Category of Personal Information | Examples |
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, telephone numbers, date of birth, other similar identifiers. |
| Categories of Personal Information described in Section 1798.80(e) of the California Civil Code | Name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history. |
| Characteristics of protected classifications under California or federal law | Age, race, national origin, citizenship, 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, military status, or any other protected characteristic in accordance with applicable Zelis policies and law. |
| Biometric Information | Fingerprint, voice recording. |
| Internet or other electronic network activity information | Your access to and use of Zelis’ communication systems, applications, and software including your access to and modification of the information contained therein (e.g. corporate, client, and member information). This includes your Zelis email account, and applies whether you access such information, systems, applications, software, and communication systems through Company issued equipment or your personal device. User logs and access control related information, including physical access to Zelis’ premises. CCTV footage and other information obtained through electronic means such as swipe card records. Geo-Location information on Zelis-owned devices (e.g., laptops to locate and/or wipe lost or stolen laptops), or other devices owned by you which you use in connection with your employment with Zelis. Browsing history and information regarding interaction with an Internet website, application, or advertisements on Zelis-provided devices. |
| Geographic data | IP address information when devices access Zelis environments; swipe card records when accessing Zelis facilities. |
| Audio, electronic, visual, thermal, olfactory, or similar information | Photograph, temperature, CCTV footage, voice recording. |
| Professional or employment-related information | Title(s), position description(s), working location(s), years of service, salary, work hours, vacation, paid time off and protected leaves or absences; copy of driving license (if relevant for your position); information related to immigration and right-to-work (e.g., work permit / visa application information); travelling and travel expenses data; termination date and reason for termination. CV/resume details, employment history, and any information you provide to us on an application and during interviews, as well as information we gather from reference persons whose contact details you have provided to us, written or verbally, and background check reports. Information required for payroll purposes (e.g., bank account details, tax information); information related to benefit entitlements, such as insurance and stock options or the like, e.g., details of participation and contributions made; benefits information, compensation information; emergency contact information, and names of dependents. Performance related information (e.g., assessments of your performance, objectives and goals, feedback, and tests results); information relating to Associate relations, misconduct, investigations, and disciplinary actions; attendance; qualifications and personal development information (e.g. career growth and development plans)and competence assessments; learning and development records, certificates, licenses, and vocational records; records of career and succession planning; ongoing background check reports and security data. |
| Education information | Degrees, schools attended, certificates, licenses, spoken languages, vocational records, and professional qualifications. |
| Inferences | Inferences drawn from any of the above types of information that may reflect your characteristics, behavior, intelligence, abilities, and aptitudes related to the purposes outlined in Section 5 below. |
| Personal Information that you provide directly to us either verbally or in writing. | |
| Categories of Sensitive Personal Information under the CCPA | Government identifiers (e.g., Social Security, driver’s license, state identification card, and passport numbers); Complete account access credentials (e.g., usernames, combined with password); citizenship or immigration status; religious or philosophical beliefs; union membership; biometric information; financial account information, precise geolocation, racial or ethnic origin, or health information; sexual orientation information. |
4. Sources of Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources which includes, but is not limited to, the following:
- Directly from you, such as from the forms or information you input into Workday.
- Indirectly from you, such as from your interactions with the Company's computer systems.
- From our service providers, such as third-party recruiting partners, background check providers, drug testing providers, insurance companies, internet service providers, data analytics providers, and operating systems and platforms.
- Government entities, such as for background check purposes.
- From other Associates, such as from performance reviews or other observations and interactions including from third-party development and assessment partners.
- Employer obtained information for purposes of contractually obligated government reporting.
As an employer, Zelis collects, uses, and discloses your Personal Information in connection with your working relationship with us and in order to comply with Zelis’ legal obligations in accordance with applicable law and contractual obligations. We use, and may disclose to third parties who assist us with these functions, Personal Information for the following purposes:
- Recruitment, interviewing, and evaluating applicants for employment;
- Background checks for employment and client engagement services;
- Performing ongoing sanction and exclusion checks, including those required by the Office of the Inspector General;
- Onboarding and decisions about continued employment or engagement;
- Managing and documenting your employment, attendance, and job performance;
- Providing you with equipment, training, and support performing your job duties and responsibilities;
- Payroll and other compensation;
- Administering and managing any and all compensation and benefits programs provided to you by Zelis;
- Organization management and administration, including staffing management, financial planning, internal audits, and other administration;
- Administration of absences in accordance with Company and statutory leave programs;
- Expense reimbursement (e.g., for travel, education, etc.);
- Responding to employment verification inquiries;
- Communicating with you. This may include facilitating communications to and between Associates and non-Associates, consultants, contractors, and communications with other bodies (e.g., regulatory authorities, third-party partners). This also includes use of your photograph on internal methods of communication including email communications, ID cards, and through other global Associate development activities such as on ZHUB, during town hall meetings, and department meetings;
- External marketing activities, including marketing photos, brochures, website content, videos, social media posts, and other related marketing activities;
- Internal communications, including photographs, ZHUB content, and videos;
- Complying with legal obligations, including responding to requests from government agencies;
- Reporting to appropriate government entities, including tax authorities and other governmental and regulatory agencies;
- Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and physical locations
- Administering our applications, software, and systems;
- Preventing fraud, responding to legal process, and complying with federal, state, and local laws, as well as regulatory requirements;
- Statistical, research, and analytical purposes to understand and improve worker satisfaction, improve products & services, and performance as necessary;
- To support Zelis’ Diversity, Equity & Inclusion (DEI) initiatives, which could include reviewing aggregate reporting to ensure equitable and inclusive practices, monitor trends and achieve organizational targets in accordance with applicable Zelis policies and law;
- Any other purpose with your consent.
We may use or disclose Sensitive Personal Information for the following statutorily approved reasons:
- Performing actions that are necessary for our employment relationship and that an average employee in an employment relationship with us would reasonably expect, including for many of the purposes listed above.
- Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
- Services performed for the Company, including maintaining or servicing accounts, providing human resources and employee benefits administration, processing or fulfilling transactions, verifying employee information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
We may disclose the Personal Information we collect, including Sensitive Personal Information, to others for the business purposes described in Section 5, such as to engage service providers to help us administer our P&C functions, benefits, or plans, etc. For example, we may disclose information from the Zelis’ equipment or your use of our network, systems, or equipment to a service provider that provides us with data and cybersecurity services.
7. Sales and Sharing of Your Personal Information
We do not sell your Personal Information to third parties. We also do not share your Personal Information with third parties for cross-context behavioral advertising purposes. To the extent you opt into text notifications from Zelis, Zelis will not disclose your opt-ins and consents to any third party unless required by legal and contractual agreements
8. Your Rights Regarding Your Personal Information
You have the following rights regarding your Personal Information maintained by Zelis:
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information, including the specific pieces of Personal Information we have collected about you. Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make two (2) right to know and data portability requests in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you the categories of:
- Personal Information we collected about you;
- sources from which we collected your Personal Information;
- the business or commercial purpose for collecting your Personal Information and, if applicable, selling or sharing your Personal Information; and
- if applicable, the third parties to whom we disclosed your Personal Information.
Right to Delete
You have the right to request Zelis to delete Personal Information collected from and about you, subject to certain exceptions and in accordance with applicable law and contractual obligations. Zelis will need to assess federal, state, and local retention requirements when responding to your deletion request. There are instances in which Zelis cannot agree to your request to delete Personal Information in accordance with applicable law and contractual obligations.
Instructions for submitting a verifiable request are provided below.
Right to Correct Inaccurate Personal Information
You have the right to request that Zelis corrects Personal Information that is inaccurate.
Instructions for submitting a verifiable request are provided below.
Right to Limit Use and Disclosure of Sensitive Personal Information to Permitted Purposes
You have the right to request that Zelis limits use and disclosure your of Sensitive Personal Information, defined above. However, this right only applies to use of Sensitive Personal Information other than what would be “reasonably expected by an average” consumer/employee, so there are some exceptions.
Right to Non-Discrimination
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under certain applicable law, including the CCPA and in accordance with applicable Zelis policies and law.
Instructions for submitting a verifiable request are provided below.
9. How to Exercise Your Rights
To submit a request to exercise any of your rights, please email privacyoffice@zelis.com.
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know or for data portability twice within a 12-month period.
Verification Process and Authorized Agents
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your Personal Information. To designate an authorized agent, please speak to your P&C partner and put in a ticket with P&C Connect. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your Personal Information.
We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the Personal Information relating to you.
Responding to Your Requests to Know, Delete, or Correct
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please email the Privacy Office at privacyoffice@zelis.com.
We strive to respond to a verifiable request within 45 days of you sending it to us. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will email you with our response, which will specify whether we can meet your request. If we cannot meet your request, either in whole or in part, we will explain the reason, subject to any legal or regulatory limitations. Some laws may permit or require us to deny access to some of the Personal Information we have about you, or we may have destroyed, deleted, or anonymized your Personal Information in accordance with our records retention policies and obligations.
For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another.
10. Retention of Personal Information
We retain your Personal Information during the course of your employment by or providing services to Zelis in accordance with applicable law and contractual obligations. We keep this information throughout your employment or application process with Zelis and for a specific time afterward in accordance with our Records Retention Policy and applicable law. This period is determined by our legal responsibilities, such as financial and equal opportunity reporting, as well as the statutory periods needed to resolve disputes, handle legal claims, perform audits, and enforce agreements.
11. Security
We have implemented reasonable measures designed to secure your Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. We also limit access to Personal Information to those Associates, agents, service providers, and contractors that have a legitimate business need for such access.
12. Contact Us
If you have any questions about our collection or use of your Personal Information, please contact the Privacy Office at privacyoffice@zelis.com or contact P&C via P&C Connect.
13. Changes to this Privacy Notice
We may periodically modify this Privacy Notice and will provide such updates to you via email, posting it on ZHUB, or by otherwise distributing this to you as part of updates to our policies and procedures.