Privacy Practices for Employee Personal Information

Teladoc Health Notice of Privacy Practices for US Employees’ Personal Information

Effective November 1, 2021

1. Introduction

Teladoc respects your privacy and is committed to maintaining the confidentiality and security of your Personal Information. In furtherance of your employment relationship with Teladoc, we collect Personal Information responsibly and in accordance with applicable data privacy laws, including but not limited to, the California Consumer Privacy Act (“CCPA”). For purposes of this 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.

The purpose of this Notice of Privacy Practices for US Employees’ Personal Information (“Notice”) is to provide notification to potential, former, and current full-time and part-time employees, volunteers, contractors, and interns (collectively referred to throughout this Notice as “you”, “your”, “their”, or “Employees”) as to how Teladoc Health, Inc. uses and discloses your Personal Information. For the purposes of this Notice, “Employee” also refers to consultants and contractors engaged by Teladoc, even though they are not otherwise employees.

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 Officer at [email protected] or by contacting your HR Representative.

This Privacy Notice is not a contract and does not create any contract of employment or other rights or obligations.

2. Scope

Teladoc Health, Inc. is made up of different legal entities, including U.S. and international subsidiaries listed in Teladoc Health Subsidiaries and Affiliates. When we mention “Teladoc”, “we”, “us” or “our” in this Notice, we are referring to the relevant legal entity of Teladoc Health, Inc. that is responsible for processing your Personal Information as your employer. This Notice applies to how Teladoc collects and uses your Personal Information as part of your employment relationship with Teladoc.

To the extent that you use any of Teladoc’s suite of medical services, such as telehealth, chronic condition management, or expert medical services, or Teladoc’s websites, this Notice does not apply to the information that is collected during your use of those services. To avoid doubt, the information collected during your use of those services, if any, will not be accessed or used for employment purposes. See the Privacy Notice that is applicable for the services you are using in order to understand what Personal Information is collected and processed by Teladoc during the course of your use of those services.

3. Categories of Personal Information We Collect

We may collect the following categories of Personal Information about you:

Category Examples
Identifiers Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, 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, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, health insurance information.
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, or military status.
Biometric information Fingerprint, voice recording.
Internet or other electronic network activity information Your access to and use of Teladoc’s 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 Teladoc 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 Teladoc’s premises. CCTV footage and other information obtained through electronic means such as swipe card records. Location information, including through GPS tracking technology on Teladoc-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 Teladoc. Browsing history, search history, and information regarding interaction with an Internet website, application, or advertisements on Teladoc-provided devices.
Geographic data GPS tracking on Teladoc-provided devices as well as through swipe card records.
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 and absences; copy of driving license (if relevant for your position); copy of passport or identity card, and 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 and schemes such as insurance and stock options, 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 misconduct, investigations, and disciplinary actions; attendance; qualifications and personal development information, 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 4 below.

Personal Information that you provide directly to us either verbally or in writing

4. Purposes for which Personal Information is Used

As an employer, Teladoc collects, uses and discloses your Personal Information in connection with your working relationship with us and in order to comply with Teladoc’s legal obligations. We use, and may disclose to third parties who assist us with these functions, Personal Information for the following purposes:

  • Recruitment, interviewing, and vetting of candidates for employment

  • Background checks for employment and client engagement services

  • Onboarding and decisions about continued employment or engagement

  • Managing and documenting your employment, attendance, and job performance

  • Providing you with equipment, training, and support to carry out your duties and responsibilities

  • Payroll and other compensation

  • Administering and managing compensation and benefits

  • 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,

  • Traveling and expense reimbursement

  • Responding to employment verification inquiries

  • Communicating with you. This may include facilitating communications to and between employees and contractors, and communications with other bodies (e.g., regulatory authorities). This also includes use of your photograph on internal methods of communication including email communications, ID cards, and through other global employee development activities such as on the Teladoc Intranet, 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.

  • 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

  • Short-term transient use

  • For any other purpose with your consent

5. Cross-Border Transfers of Personal Information

Teladoc is a global company, with offices located throughout the world. As a result, your Personal Information may be transferred to other Teladoc offices for the purposes identified above. Any such transfer shall take place only in accordance with and as permitted by the law of your jurisdiction, but please be aware that the laws and practices relating to the protection of Personal Information may be different. Regardless, we shall apply the provisions of this Notice to your Personal Information wherever it is located. Teladoc may use third parties, for purposes described above, that reside outside of your jurisdiction.

6. Retention of Personal Information

The length of time we retain your Personal Information depends on the status of our relationship with you and the requirements of applicable law. We will retain your Personal Information for as long as your employment with us lasts and for a certain period after your employment with us has ended. To determine that period, we take into account our legal and regulatory obligations (such as financial, equal opportunity, and antidiscrimination reporting obligations) and for the statutory periods necessary to resolve disputes, make and defend legal claims, conduct audits, and/or enforce our agreements.

7. Security

We take reasonable precautions designed to protect Personal Information in our possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Access to our systems that store your Personal Information is restricted by means of a user ID and password that are issued only to authorized personnel. In turn, to assist in safeguarding this information, you need to select and protect your password appropriately and limit access to your computer and browser, including by signing off after you have accessed Personal Information.

8. Contact Us

If you have any questions about our collection or use of your Personal Information, please contact the Privacy Officer at [email protected] or contact your HR Representative.

9. Changes to this Privacy Notice

We may periodically modify this Privacy Notice and promptly will provide such updates to you via email, posting it on a Teladoc Intranet site, or by otherwise distributing this to you as part of updates to our policies and procedures.