Notice of Privacy Practices

At 3 Cube Life, we are committed to protecting the information you provide us with. This notice outlines what information will be collected, how it will be used, who will receive it, and what will be done to keep it confidential.

NOTICE REGARDING WELLNESS PROGRAM

3 Cube Life is a voluntary wellness program available to all eligible employees. The program is administered according to federal rules permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease, including the Americans with Disabilities Act of 1990, the Genetic Information Nondiscrimination Act of 2008, and the Health Insurance Portability and Accountability Act, as applicable, among others. If you choose to participate in the wellness program you will be asked to complete a voluntary “Look at Me” and a Medical survey that asks a series of questions about your health-related activities and behaviors and whether you have or had certain medical conditions (e.g., cancer, diabetes, or heart disease). You will also be asked to complete a biometric health check which will include a blood test for cholesterol and glucose, other tests will consist of blood pressure, bio-impedance body fat analysis, calculated BMI and waist circumference upon request. You are not required to complete the Look at Me, Medical Survey or to participate in the biometric health check.

However, employees who choose to participate in the wellness program will receive a personalized video from one of our Doctors explaining your results in detail, access to videos, blogs and newsletters on numerous health related topics and health challenges to keep you engaged as you improve your health.

The information from “Look at Me”, your Medical Survey and the results from your health check will be used to provide you with information to help you understand your current health and potential risks and may also be used to offer you services through the wellness program, such as coaching calls with our health guide. You are encouraged to share your results or concerns with your own doctor.

Protections from Disclosure of Medical Information

We are required by law to maintain the privacy and security of your personally identifiable health information. Although the 3 Cube Life and your employer may use aggregate information it collects to design a program based on identified health risks in the workplace, 3 Cube Life will never disclose any of your personal information either publicly or to the employer, except as necessary to respond to a request from you for a reasonable accommodation needed to participate in the wellness program, or as expressly permitted by law. Medical information that personally identifies you that is provided in connection with the wellness program will not be provided to your supervisors or managers and may never be used to make decisions regarding your employment.

Your health information will not be sold, exchanged, transferred, or otherwise disclosed except to the extent permitted by law to carry out specific activities related to the wellness program, and you will not be asked or required to waive the confidentiality of your health information as a condition of participating in the wellness program or receiving an incentive. Anyone who receives your information for purposes of providing you services as part of the wellness program will abide by the same confidentiality requirements. The only individuals who will receive your personally identifiable health information are our Health Check Technician, Health Promotion Director, Doctor on staff and Health Guide in order to provide you with services under the wellness program.

In addition, all medical information obtained through the wellness program will be maintained separate from your personnel records, information stored electronically will be encrypted, and no information you provide as part of the wellness program will be used in making any employment decision. Appropriate precautions will be taken to avoid any data breach, and in the event a data breach occurs involving information you provide in connection with the wellness program, we will notify you immediately.

You may not be discriminated against in employment because of the medical information you provide as part of participating in the wellness program, nor may you be subjected to retaliation if you choose not to participate.

If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact [insert name of appropriate contact] at [contact information].